DOJ-OGR-00003025.jpg
622 KB
Extraction Summary
8
People
3
Organizations
0
Locations
6
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
622 KB
Summary
This legal document, filed on April 16, 2021, recounts events from 2016 concerning the civil litigation between Giuffre and Maxwell. It details the process of establishing a protective order for discovery materials, initiated by Maxwell's motion on March 2, 2016, contested by Giuffre's counsel (Boies Schiller), and ultimately entered by Judge Robert W. Sweet on March 18, 2016. The document also asserts that the USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016 and that the government has no record of email communication between AUSA-1 and Boies Schiller attorneys after May 3, 2016.
People (8)
| Name | Role | Context |
|---|---|---|
| AUSA-1 | Assistant United States Attorney |
Mentioned as not recalling details of a conversation and having no identified email communication with Boies Schiller...
|
| Pottinger | attorney |
Mentioned as an attorney at Boies Schiller with whom AUSA-1 did not have identified email communication after May 3, ...
|
| Edwards | attorney |
Mentioned as an attorney at Boies Schiller with whom AUSA-1 did not have identified email communication after May 3, ...
|
| Skinner | attorney |
Mentioned as an attorney at Boies Schiller with whom AUSA-1 did not have identified email communication after May 3, ...
|
| Epstein |
Mentioned in the context that the USAO-SDNY did not open an investigation into him in 2016.
|
|
| Maxwell | Defendant |
Subject of depositions in April and July 2016; moved for a protective order in the Giuffre v. Maxwell civil litigation.
|
| Robert W. Sweet | United States District Judge |
Mentioned as the judge overseeing the Giuffre v. Maxwell civil litigation who entered a protective order on March 18,...
|
| Giuffre | Plaintiff |
Party in the Giuffre v. Maxwell civil litigation. Represented by Boies Schiller, she opposed the form of a protective...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Stated as not being aware of records documenting a call and not having identified records of email communication from...
|
| Boies Schiller | company |
Law firm representing Giuffre in the civil litigation against Maxwell. They opposed the form of Maxwell's proposed pr...
|
| USAO-SDNY | government agency |
The United States Attorney's Office for the Southern District of New York, which reportedly did not open an investiga...
|
Timeline (6 events)
2016-03-04
Boies Schiller, on behalf of Giuffre, represented that they did not oppose a protective order but opposed the specific form proposed by Maxwell.
2016-03-18
Judge Sweet entered a protective order governing discovery and dissemination of confidential information in the Giuffre v. Maxwell case.
Relationships (3)
Giuffre was the plaintiff and Maxwell the defendant in the 'Giuffre v. Maxwell civil litigation'.
The document states that 'Boies Schiller represented that Giuffre did not oppose the entry of a protective order'.
Judge Sweet was 'overseeing the Giuffre v. Maxwell civil litigation' and 'entered a protective order'.
Full Extracted Text
Complete text extracted from the document (1,757 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 91 of 239
Ex. 7), but AUSA-1 does not recall the details of that conversation (see Ex. 4 at 4), nor is the
Government aware of any notes or other records documenting the substance of the call. The
Government has not identified any records that suggest AUSA-1 ever communicated via email
with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after
May 3, 2016.
The USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016. (Id. at
4).
Government aware of any notes or other records documenting the substance of the call. The
Government has not identified any records that suggest AUSA-1 ever communicated via email
with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after
May 3, 2016.
The USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016. (Id. at
4).
3. The April and July 2016 Depositions of Maxwell
On March 2, 2016, Maxwell moved for entry of a protective order for materials produced
in discovery and submitted a proposed order for the consideration of the Honorable Robert W.
Sweet, the United States District Judge who was then overseeing the Giuffre v. Maxwell civil
litigation. (See 15 Civ. 7433 (LAP), Dkt. Nos. 38 & 39-1). On or about March 4, 2016, Boies
Schiller represented that Giuffre did not oppose the entry of a protective order, but opposed the
form proposed by Maxwell out of concern that it was overly broad and could lead to over-
designation of material as confidential. (See 15 Civ. 7433 (LAP), Dkt. No. 40 at 2). Boies Schiller
submitted a redline of Maxwell’s proposed protective order, deleting some provisions and adding
language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B).
On March 18, 2016, Judge Sweet entered a protective order governing the discovery and
dissemination of confidential information after the parties agreed to the form of the order originally
proposed by Maxwell. (See 15 Civ. 7433 (LAP), Dkt. No. 62; see also Def. Mot. 3, Ex. G at 2-3).
in discovery and submitted a proposed order for the consideration of the Honorable Robert W.
Sweet, the United States District Judge who was then overseeing the Giuffre v. Maxwell civil
litigation. (See 15 Civ. 7433 (LAP), Dkt. Nos. 38 & 39-1). On or about March 4, 2016, Boies
Schiller represented that Giuffre did not oppose the entry of a protective order, but opposed the
form proposed by Maxwell out of concern that it was overly broad and could lead to over-
designation of material as confidential. (See 15 Civ. 7433 (LAP), Dkt. No. 40 at 2). Boies Schiller
submitted a redline of Maxwell’s proposed protective order, deleting some provisions and adding
language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B).
On March 18, 2016, Judge Sweet entered a protective order governing the discovery and
dissemination of confidential information after the parties agreed to the form of the order originally
proposed by Maxwell. (See 15 Civ. 7433 (LAP), Dkt. No. 62; see also Def. Mot. 3, Ex. G at 2-3).
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DOJ-OGR-00003025
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