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757 KB
Extraction Summary
3
People
1
Organizations
1
Locations
2
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
757 KB
Summary
This legal document, dated July 27, 2020, is a filing to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The filing argues in favor of Maxwell's proposed protective order, which would allow her defense team to publicly reference alleged victims or witnesses who have already spoken on the public record regarding Maxwell or Jeffrey Epstein. It contrasts this with the government's more restrictive proposal, arguing the government's position is 'broader than necessary' and would hinder the defense's ability to prepare for trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Recipient of the letter/filing.
|
| Ghislaine Maxwell | Defendant |
Referred to as Ms. Maxwell. The subject of the criminal case and the proposed protective order.
|
| Jeffrey Epstein | Individual related to the case |
Referred to as Mr. Epstein. His previous criminal prosecution is cited as a precedent for a protective order.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| S.D.N.Y. | government agency |
The court where the case United States v. Epstein was heard (Southern District of New York).
|
Timeline (2 events)
2019-07-25
A protective order was approved in the government's criminal prosecution of Mr. Epstein.
S.D.N.Y.
Mr. Epstein
United States government
2020-07-27
Document 29 was filed in Case 1:20-cr-00330-AJN.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the citation for the United States v. Epstein case.
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Relationships (1)
The document discusses litigation relating to both Jeffrey Epstein and Ghislaine Maxwell, and mentions civil suits against them.
Key Quotes (2)
"who have spoken on the public record to the media or in public fora, or in litigation—criminal or otherwise—relating to Jeffrey Epstein or Ghislaine Maxwell."Source
— Ms. Maxwell's proposed protective order (quoted in the document)
(This is the language from Ms. Maxwell's proposed protective order that defines which individuals the defense counsel is not prohibited from publicly referencing.)
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Quote #1
"broader than necessary"Source
— The author of the document (Ms. Maxwell's defense counsel)
(Describing the government's proposed restriction on the defense's ability to reference individuals who have already self-identified.)
DOJ-OGR-00001645.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,233 characters)
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 3 of 4
The Honorable Alison J. Nathan
July 27, 2020
Page 3
July 27, 2020
Page 3
Maxwell with respect to using the criminal discovery material solely for the purpose of this criminal case.
2. Victim/Witness Identities
Ms. Maxwell’s proposed protective order prohibits Ms. Maxwell, defense counsel, and others on the defense team from disclosing or disseminating the identity of any alleged victim or potential witness referenced in the discovery materials, but does not prohibit defense counsel from publicly referencing individuals “who have spoken on the public record to the media or in public fora, or in litigation—criminal or otherwise—relating to Jeffrey Epstein or Ghislaine Maxwell.” Id. ¶ 6. This language, which is nearly identical in all material respects to the language in the protective order approved in the government’s criminal prosecution of Mr. Epstein, see United States v. Epstein, 19-CR-00490-RMB (S.D.N.Y. July 25, 2019), ensures appropriate privacy protections for alleged victims and should be approved here.
In contrast to the more permissive language it agreed to with respect to Mr. Epstein, the government has taken the position that Ms. Maxwell’s defense counsel should only be allowed to disclose the identity of alleged victims or potential witnesses who have spoken by name on the public record “in this case.” The government’s proposal, however, advances no compelling privacy protections, and instead prevents the defense from making reference to individuals who have already voluntarily publicly disclosed their identities by, among other things, pursuing civil suits in their own name against Ms. Maxwell and/or Mr. Epstein; speaking by name in the public record in Mr. Epstein’s criminal proceedings; participating in on-the-record media interviews; or posting comments under their own names on social media. The government’s proposed restriction is therefore “broader than necessary” to protect the privacy interests of these individuals who have already chosen to self-identify, and will hinder the defense’s ability to conduct further factual investigation, prepare witnesses for trial, and advocate on Ms. Maxwell’s behalf.
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DOJ-OGR-00001645
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