DOJ-OGR-00008374.jpg
552 KB
Extraction Summary
5
People
4
Organizations
4
Locations
1
Events
8
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
552 KB
Summary
This legal letter from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 14, 2021, opposes defendant Ghislaine Maxwell's request to call three attorneys for victims (Jack Scarola, Brad Edwards, and Robert Glassman) to testify. The Government argues that their testimony about privileged client conversations or discussions with the Government would be irrelevant and an improper attempt to circumvent privilege, as the victims themselves have already testified.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The Honorable Alison J. Nathan, United States District Court Judge, recipient of the letter.
|
| Ghislaine Maxwell | Defendant |
Defendant in the case United States v. Ghislaine Maxwell, whose request the letter opposes.
|
| Jack Scarola | Counsel for victims |
Attorney whom the defendant requested to call to testify in the case-in-chief.
|
| Brad Edwards | Counsel for victims |
Attorney whom the defendant requested to call to testify in the case-in-chief.
|
| Robert Glassman | Counsel for victims |
Attorney whom the defendant requested to call to testify in the case-in-chief.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | Government agency |
Header of the document, indicating the sender of the letter.
|
| United States Attorney | Government agency |
Part of the U.S. Department of Justice, sender of the letter.
|
| Southern District of New York | Government agency |
The specific district of the United States Attorney's office and the United States District Court.
|
| United States District Court | Judicial body |
The court where Judge Nathan presides and where the case is being heard.
|
Timeline (1 events)
The defendant, Ghislaine Maxwell, made a request to call Jack Scarola, Brad Edwards, and Robert Glassman (counsel for victims) to testify in her case-in-chief. The Government submitted this letter in opposition to that request.
United States District Court, Southern District of New York
Locations (4)
| Location | Context |
|---|---|
|
Address of the United States Attorney, Southern District of New York.
|
|
|
Address of the United States Attorney, Southern District of New York.
|
|
|
Location of the United States Attorney's office and the United States Courthouse.
|
|
|
Address of the United States Courthouse.
|
Relationships (8)
The Government addresses the letter to Judge Nathan, submitting a legal argument to her court.
The case is 'United States v. Ghislaine Maxwell', and 'The Government respectfully submits this letter in opposition to the defendant's request'.
The defendant requested to call Jack Scarola, counsel for victims, to testify.
The defendant requested to call Brad Edwards, counsel for victims, to testify.
The defendant requested to call Robert Glassman, counsel for victims, to testify.
Described as 'counsel for victims'.
Described as 'counsel for victims'.
Described as 'counsel for victims'.
Full Extracted Text
Complete text extracted from the document (1,445 characters)
Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 1 of 9
U.S. Department of Justice
United States Attorney
Southern District of New York
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
One Saint Andrew's Plaza
New York, New York 10007
December 14, 2021
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant's request to
call Jack Scarola, Brad Edwards, and Robert Glassman—all counsel for victims—to testify in the
defendant's case-in-chief. Rather than asking these attorneys about their conversations with their
clients, which are privileged, the defendant seeks to elicit testimony about those attorneys'
conversations with the Government. This end-run around privilege, however, would only generate
irrelevant evidence. The victims themselves have testified and been cross-examined about what
they do and do not know or believe. There is no relevance to their lawyers' conversations with
the Government when the defendant has failed to establish the victim's knowledge of those
statements, nor would testimony about those conversations serve as proper impeachment, unless
those conversations were in some way communicated to their clients. And that fact has not been
call Jack Scarola, Brad Edwards, and Robert Glassman—all counsel for victims—to testify in the
defendant's case-in-chief. Rather than asking these attorneys about their conversations with their
clients, which are privileged, the defendant seeks to elicit testimony about those attorneys'
conversations with the Government. This end-run around privilege, however, would only generate
irrelevant evidence. The victims themselves have testified and been cross-examined about what
they do and do not know or believe. There is no relevance to their lawyers' conversations with
the Government when the defendant has failed to establish the victim's knowledge of those
statements, nor would testimony about those conversations serve as proper impeachment, unless
those conversations were in some way communicated to their clients. And that fact has not been
1
DOJ-OGR-00008374
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document