EFTA00029816.pdf

1.37 MB
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Extraction Summary

13
People
6
Organizations
2
Locations
4
Events
2
Relationships
5
Quotes

Document Information

Type: Legal memorandum (motion to suppress evidence)
File Size: 1.37 MB
Summary

This document is a legal memorandum filed by Ghislaine Maxwell's defense team on January 25, 2021, seeking to suppress evidence obtained via subpoena from the law firm Boies Schiller Flexner. The defense argues that the government made false representations to Judge McMahon to bypass a civil protective order and obtain confidential deposition transcripts, alleging collusion between the civil plaintiff's lawyers (Boies Schiller) and federal prosecutors. The document details the history of the civil defamation case, specific deposition questions regarding sexual acts and Epstein, and the procedural history of the protective order modification.

People (13)

Name Role Context
Ghislaine Maxwell Defendant
Filing motion to suppress evidence and dismiss counts 5 and 6.
Jeffrey Epstein Associate
Mentioned as the primary subject of investigation and alleged abuse.
Judge McMahon Judge (SDNY)
Chief Judge who modified the protective order based on government representations.
Judge Netburn Magistrate Judge
Judge in a parallel civil case who rejected a similar government request.
David Boies Attorney
Partner at Boies Schiller Flexner LLP; allegedly approached government to instigate prosecution.
Amanda Kramer Assistant U.S. Attorney
Met with Boies Schiller attorneys in February 2016 regarding Epstein/Maxwell.
Jeffrey S. Pagliuca Defense Attorney
Attorney for Ghislaine Maxwell (Haddon, Morgan & Foreman).
Laura A. Menninger Defense Attorney
Attorney for Ghislaine Maxwell (Haddon, Morgan & Foreman).
Mark S. Cohen Defense Attorney
Attorney for Ghislaine Maxwell (Cohen & Gresser LLP).
Christian R. Everdell Defense Attorney
Attorney for Ghislaine Maxwell (Cohen & Gresser LLP).
Bobbi C. Sternheim Defense Attorney
Attorney for Ghislaine Maxwell.
[Redacted] (Virginia Giuffre) Civil Plaintiff
Plaintiff in the 2015 defamation suit (name redacted in document but contextually clear).
Accuser-1, Accuser-2, Accuser-3 Victims/Witnesses
Referred to in the indictment as Minor Victim-1, 2, 3.

Timeline (4 events)

2015
Filing of civil defamation case [Redacted] v. Maxwell.
SDNY
[Redacted] Ghislaine Maxwell
2016-04
Maxwell's first civil deposition.
Unknown
Ghislaine Maxwell Boies Schiller attorneys
2016-07
Maxwell's second civil deposition regarding sexual activities.
Unknown
Ghislaine Maxwell Boies Schiller attorneys
2019-04-09
Hearing before Judge McMahon regarding modification of protective order.
SDNY Court
Judge McMahon Assistant U.S. Attorney

Locations (2)

Relationships (2)

Boies Schiller Flexner LLP Collusion/Cooperation United States Attorney's Office
Defense alleges Boies Schiller 'fomented' the investigation and provided documents to the government despite a protective order.
Ghislaine Maxwell Co-conspirator/Associate Jeffrey Epstein
Maxwell deposed about sexual activities involving Epstein and minors.

Key Quotes (5)

"We have her dead to rights."
Source
EFTA00029816.pdf
Quote #1
"I don't know what you're talking about."
Source
EFTA00029816.pdf
Quote #2
"I'm not aware of anybody that I interacted with, other than obviously [Redacted] who was 17 at this point."
Source
EFTA00029816.pdf
Quote #3
"sexually abused and trafficked"
Source
EFTA00029816.pdf
Quote #4
"Every word of the government’s representation was untrue, 'including 'and' and 'the.''"
Source
EFTA00029816.pdf
Quote #5

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