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1.17 MB
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Extraction Summary

4
People
4
Organizations
1
Locations
2
Events
3
Relationships
5
Quotes

Document Information

Type: Legal correspondence / court filing (letter to judge)
File Size: 1.17 MB
Summary

This document is a legal letter to Judge Alison J. Nathan arguing against a subpoena issued by the Defendant (Ghislaine Maxwell) to the law firm BSF. The author argues that requests for materials related to the Epstein Victim's Compensation Program (EVCP) and communications between BSF and the U.S. Attorney are irrelevant to the charges, protected by work-product privilege, and constitute a 'fishing expedition' intended to support a false narrative of collusion. The document specifically details Requests 1, 3-5, 8, and 12.

People (4)

Name Role Context
Alison J. Nathan Judge
Recipient of the letter (The Honorable)
Ghislaine Maxwell Defendant
Referred to as 'the Defendant'; explicitly named in footnote relating to legal matters.
Jeffrey Epstein Deceased / Accused
Mentioned in relation to the Victim's Compensation Program and past legal matters.
BSF Legal Counsel (Third Party)
Law firm (Boies Schiller Flexner) representing victims; subject of the subpoena requests.

Organizations (4)

Name Type Context
Epstein Victim's Compensation Program Compensation Fund
Subject of Request 12; referred to as 'EVCP Material'.
BSF Law Firm
Boies Schiller Flexner (implied); firm served with subpoenas.
U.S. Attorney's Office Government Agency
Prosecution; mentioned regarding communications with BSF.
Government Government
Prosecution team in the criminal case.

Timeline (2 events)

1994 to 1997
Period during which the Government alleges the Defendant enticed and transported minors.
N/A
March 30, 2021
Date the document was filed.
Court

Locations (1)

Location Context
Eastern District of New York, cited in case law (United States v. Weisberg).

Relationships (3)

Ghislaine Maxwell Adversarial BSF
Defendant accuses BSF of collusion with the Government; BSF is fighting Defendant's subpoenas.
BSF Professional/Legal U.S. Attorney
Communications sought between BSF and U.S. Attorney regarding the Defendant.
Jeffrey Epstein Co-defendants/Associates Ghislaine Maxwell
Mentioned together in context of legal matters and accusations.

Key Quotes (5)

"Request 12 asks for 'EVCP Material,' which is defined as 'any submission to the Epstein Victim’s Compensation Program made by You...'"
Source
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Quote #1
"accurately described as a fishing expedition."
Source
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Quote #2
"The Defendant cannot merely request every piece of confidential information that BSF submitted to the Program in the hopes that something relevant and admissible turns up."
Source
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Quote #3
"relevant to the Defendant’s false narrative that BSF somehow colluded with the Government"
Source
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Quote #4
"Requests 3 through 5 also seek protected work product."
Source
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Quote #5

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