036.pdf
228 KB
Extraction Summary
8
People
4
Organizations
5
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing (defendant's sur-reply to supplemental reply)
File Size:
228 KB
Summary
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
People (8)
| Name | Role | Context |
|---|---|---|
| Bradley J. Edwards | Plaintiff |
Party resisting production of solicitation letters sent to potential witnesses.
|
| Ghislaine Maxwell | Defendant |
Party seeking production of documents from Edwards.
|
| Jeffrey Epstein | Former Employer |
Mentioned as the former employer of individuals to whom Edwards sent solicitation letters.
|
| Jeffrey S. Pagliuca | Attorney |
Attorney for Ghislaine Maxwell, author of the filing.
|
| Denise D. Riley | Attorney |
Attorney for Ghislaine Maxwell.
|
| Paul G. Cassell | Attorney |
Recipient of service.
|
| Jack Scarola | Attorney |
Recipient of service.
|
| Nicole Simmons | Signatory |
Signed the Certificate of Service.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the case is filed.
|
|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing Ghislaine Maxwell.
|
|
| Riley Law PLLC |
Law firm representing Ghislaine Maxwell.
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm associated with Jack Scarola.
|
Timeline (2 events)
2016-06-16
2017-03-20
Filing of Defendant's Sur-Reply to Supplemental Reply
Southern District of New York
Locations (5)
| Location | Context |
|---|---|
|
Location of the District Court.
|
|
|
Office location for Jeffrey S. Pagliuca.
|
|
|
Office location for Denise D. Riley.
|
|
|
Address for Paul G. Cassell.
|
|
|
Office location for Jack Scarola.
|
Relationships (2)
Edwards sent solicitation letters to Epstein's former employees seeking information.
Plaintiff and Defendant in Case 1:17-mc-00025-RWS.
Key Quotes (5)
"Mr. Edwards knows that he sent a form solicitation letter to many individuals, including former Epstein employees, requesting their assistance as a witness in this case."Source
036.pdf
Quote #1
"Mr. Edwards, in these form letters, is essentially attempting to 'guilt' witnesses into contacting him."Source
036.pdf
Quote #2
"The solicitation letters at issue here are not work product."Source
036.pdf
Quote #3
"Mr. Edwards has no claim that what a prospective witness writes back to him is 'work product'."Source
036.pdf
Quote #4
"It requests whatever response Mr. Edwards received from the solicitation."Source
036.pdf
Quote #5
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document