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Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
669 KB
Summary
This legal document, filed on February 4, 2021, discusses Ghislaine Maxwell's depositions from April and July 2016. It outlines the terms of a Protective Order for confidential materials and describes a motion by Virginia Giuffre's lawyers (Boies Schiller) to compel Maxwell to answer questions, with assurances that her answers would remain confidential. A footnote alleges that Giuffre's side had previously leaked confidential information to the media and the government.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Boies Schiller | Law firm |
Assured the district court that questions for Maxwell were appropriate and answers would be kept confidential under t...
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| government | Government agency |
Mentioned in a footnote as a recipient of allegedly leaked confidential material.
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Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
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Boies Schiller assured the district court regarding the confidentiality of answers in the case.
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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
— Protective Order, paragraph 12
(Quoted from a legal order to describe the rules for handling confidential materials at the end of the case.)
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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
(An assurance made to the district court in support of a motion to compel Maxwell to answer questions.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (1,755 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:
[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.
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]
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.”
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.
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DOJ-OGR-00002356
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