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669 KB
Extraction Summary
5
People
3
Organizations
0
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
669 KB
Summary
This document, a legal filing from February 2021, discusses the handling of confidential material under a Protective Order and details events surrounding Maxwell's April and July 2016 depositions. It notes Maxwell's agreement to testify without invoking self-incrimination privilege and Giuffre's subsequent motion to compel further answers. A footnote also highlights concerns about the misuse and leaking of confidential information by the plaintiff and her lawyers to the media, other claimants, and the government.
People (5)
| Name | Role | Context |
|---|---|---|
| Maxwell |
Declined to invoke privilege against self-incrimination but agreed to testify at April 2016 deposition; subject of Gi...
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| Giuffre |
Moved to compel Maxwell to answer additional questions following a deposition.
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| Plaintiff |
Mentioned in footnote 2 as having concerns about misuse and abuse of information, including misleading leaking of con...
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| Lawyers |
Mentioned in footnote 2 as having concerns about misuse and abuse of information, including misleading leaking of con...
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| Claimants |
Mentioned in footnote 2 as "other false claimants" in the context of misleading leaking of confidential material.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Boies Schiller | Law Firm |
Assured the district court that certain questions for Maxwell were appropriate.
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| District Court | Government Agency |
The judicial body that Boies Schiller assured regarding the appropriateness of questions.
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| Government | Government Agency |
Mentioned in footnote 2 regarding concerns about misleading leaking of confidential material.
|
Timeline (3 events)
Key Quotes (2)
"[a]t the conclusion of this case, unless other arrangements are agreed upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents, the destroying party shall provide all parties with an affidavit confirming destruction."Source
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Quote #1
"[s]uch questions are entirely appropriate in the discovery phase of this case, particularly where any answers will be maintained as confidential under the Protective Order in this case."Source
— Boies Schiller
(Statement made to the district court in support of Giuffre's motion to compel Maxwell.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (1,799 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 9 of 23
this proposal, and it was never included in the Protective Order. Ex. A.² To the contrary, the
order strictly limited the parties’ disposition of Confidential Material, including at the conclusion
of the case. In particular, paragraph 12 of the order provided that:
order strictly limited the parties’ disposition of Confidential Material, including at the conclusion
of the case. In particular, paragraph 12 of the order provided that:
[a]t the conclusion of this case, unless other arrangements are agreed upon, each
document and all copies thereof which have been designated as CONFIDENTIAL
shall be returned to the party that designated it CONFIDENTIAL, or the parties
may elect to destroy CONFIDENTIAL documents. Where the parties agree to
destroy CONFIDENTIAL documents, the destroying party shall provide all parties
with an affidavit confirming destruction.
document and all copies thereof which have been designated as CONFIDENTIAL
shall be returned to the party that designated it CONFIDENTIAL, or the parties
may elect to destroy CONFIDENTIAL documents. Where the parties agree to
destroy CONFIDENTIAL documents, the destroying party shall provide all parties
with an affidavit confirming destruction.
Ex. A ¶ 12.
B. Maxwell’s April and July 2016 depositions
Relying on the confidentiality protections of the Protective Order, Maxwell declined to
invoke her privilege against compulsory self-incrimination and agreed to testify at her April
2016 deposition. In that deposition, [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
invoke her privilege against compulsory self-incrimination and agreed to testify at her April
2016 deposition. In that deposition, [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
Following the deposition, Giuffre moved to compel Maxwell to answer additional
intimate and personal questions that she had previously declined to answer. In support of the
motion, Boies Schiller assured the district court that “[s]uch questions are entirely appropriate in
the discovery phase of this case, particularly where any answers will be maintained as
confidential under the Protective Order in this case.”
intimate and personal questions that she had previously declined to answer. In support of the
motion, Boies Schiller assured the district court that “[s]uch questions are entirely appropriate in
the discovery phase of this case, particularly where any answers will be maintained as
confidential under the Protective Order in this case.”
² This proposal was rejected because of justifiable concerns about the misuse and abuse of this
information by plaintiff and her lawyers including the selection and misleading leaking of confidential
material to the media, other false claimants, and the government.
information by plaintiff and her lawyers including the selection and misleading leaking of confidential
material to the media, other false claimants, and the government.
4
DOJ-OGR-00002356
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