DOJ-OGR-00008365.jpg
621 KB
Extraction Summary
12
People
2
Organizations
1
Locations
2
Events
5
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
621 KB
Summary
This legal document, dated December 13, 2021, is a filing on behalf of Ms. Maxwell addressed to Judge Alison J. Nathan. The defense argues that the Court should permit the testimony of three witnesses—Mr. Scarola, Mr. Edwards, and Mr. Glassman—to establish motive and bias of Maxwell's accusers, after the government refused to stipulate. The document details the proposed testimony of attorney Jack Scarola, including his prior representation of an accuser named 'Carolyn' in a civil suit against Jeffrey Epstein and his communications with the government.
People (12)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Recipient of the document.
|
| Ms. Maxwell | Defendant |
The subject of the legal proceedings, seeking to call witnesses to testify on her behalf.
|
| Mr. Scarola | Attorney / Witness |
An attorney Ms. Maxwell wishes to call as a witness. He previously represented 'Carolyn' and communicated with the go...
|
| Mr. Edwards | Attorney / Witness |
An attorney Ms. Maxwell wishes to call as a witness. He represented alleged victims of Jeffrey Epstein.
|
| Mr. Glassman | Witness |
A person Ms. Maxwell wishes to call as a witness.
|
| Jack Scarola | Attorney |
Full name for Mr. Scarola, the subject of section A, who is an attorney licensed in Florida and represented 'Carolyn'.
|
| Carolyn | Client / Accuser |
A client represented by Mr. Scarola in a civil lawsuit against Mr. Epstein and Sarah Kellen.
|
| Mr. Epstein | Defendant in a civil lawsuit |
Named as a defendant in a civil lawsuit brought by Carolyn in 2008 and 2009.
|
| Sarah Kellen | Defendant in a civil lawsuit |
Named as a defendant alongside Mr. Epstein in a civil lawsuit brought by Carolyn.
|
| Rossmiller | Assistant United States Attorney |
Recipient of an email from Mr. Scarola in August 2019.
|
| Jeffrey Epstein |
Mentioned as the person against whom several alleged victims, represented by various attorneys, had claims.
|
|
| Robert C. Josefsberg | Attorney |
An attorney who represented alleged victims of Jeffrey Epstein and was copied on an email from Mr. Scarola.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Refers to the prosecution in the case against Ms. Maxwell, which has refused to stipulate to witness testimony.
|
| Court | Judicial body |
The judicial body presiding over the case, which Ms. Maxwell's counsel is petitioning to permit witnesses.
|
Timeline (2 events)
2008 and 2009
Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah Kellen.
2021-12-13
Ms. Maxwell's legal team requests permission from the Court to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses, after the government refused to stipulate to their testimony.
Court
Locations (1)
| Location | Context |
|---|---|
|
The state where Mr. Scarola is licensed to practice law.
|
Relationships (5)
Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah Kellen in 2008 and 2009.
Mr. Scarola acted as a 'conduit between Carolyn and the government' and sent an email to Assistant United States Attorney Rossmiller.
The document details a dispute where Ms. Maxwell seeks to call witnesses and the government (prosecution) refuses to stipulate to their testimony.
Both are attorneys who represented alleged victims of Jeffrey Epstein, and Josefsberg was copied on an email sent by Scarola.
Both are attorneys who represented alleged victims of Jeffrey Epstein, and Edwards was copied on an email sent by Scarola.
Full Extracted Text
Complete text extracted from the document (1,742 characters)
Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 2 of 9
The Honorable Alison J. Nathan
December 13, 2021
Page 2
December 13, 2021
Page 2
attorneys themselves and agents of the government, and all are relevant to show how and why Ms. Maxwell’s accusers came to cooperate with the prosecution and testify against Ms. Maxwell. The questions are relevant to motive and bias, and because the answers are not privileged, this Court should permit Ms. Maxwell to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses.
Despite this Court’s invitation, the government refused to stipulate to the testimony Ms. Maxwell seeks from Mr. Glassman. In an effort to avoid a dispute, Ms. Maxwell also inquired whether the government would be willing to stipulate as to Mr. Scarola’s and Mr. Edwards’ testimony. Without disputing Ms. Maxwell’s contention that their testimony is not shielded by the attorney-client privilege, the government nonetheless again refused to stipulate.
A. Jack Scarola
Ms. Maxwell anticipates that Mr. Scarola would be questioned on the following non-privileged topics, which primarily relate to his acting as a conduit between Carolyn and the government. All the information Ms. Maxwell seeks to elicit taken from government 3500 disclosures about Carolyn. The essence of the testimony is the following:
• Mr. Scarola is an attorney licensed to practice law in the state of Florida.
• Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah Kellen in 2008 and 2009.
• Mr. Scarola sent an email to Assistant United States Attorney Rossmiller in August 2019, copying other attorneys who represented alleged victims of Jeffrey Epstein, including Robert C. Josefsberg and Mr. Edwards.
DOJ-OGR-00008365
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