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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:
746 KB
Summary
This legal document describes the contentious discovery phase of a lawsuit between Giuffre and Maxwell. It highlights that Giuffre's law firm, Boies Schiller, attempted to use the lawsuit as a 'proxy prosecution of Epstein' and sought to include a 'law enforcement' exception in the protective order to share information with the government, a proposal Maxwell rejected. The document emphasizes the vast and sensitive nature of the information exchanged, citing a related case to describe the discovery as 'hard-fought' and 'extensive'.
People (4)
| Name | Role | Context |
|---|---|---|
| Giuffre | Public figure / Litigant |
A party in a lawsuit against Maxwell, described as a public figure who had to acknowledge some public statements were...
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| Epstein |
Mentioned as the target of a 'proxy prosecution' via Giuffre's lawsuit.
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| Maxwell | Litigant |
A party in a lawsuit with Giuffre. Was deposed and exchanged confidential information during discovery. Rejected a pr...
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| Brown | Litigant |
Mentioned in the case citation 'Brown v. Maxwell', indicating they were a party in a related or precedent-setting case.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Boies Schiller | law firm |
Represented Giuffre in her lawsuit. Accused of using a litigation tactic to turn the lawsuit into a proxy prosecution...
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| government | government agency |
Mentioned in the context of Boies Schiller being 'eager to enlist the government in its campaign against Maxwell'.
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| law enforcement | government agency |
Mentioned in a proposed exception to the Protective Order that would allow confidential information to be used for 'i...
|
Timeline (4 events)
A lawsuit between Giuffre and Maxwell, which involved a bitter, hard-fought, and wide-ranging discovery process spanning over a year.
The parties entered a stipulated Protective Order. Boies Schiller proposed adding a 'law enforcement' exception, which Maxwell rejected.
Relationships (3)
They were opposing parties in a lawsuit with a 'bitter, hard-fought' discovery process.
Boies Schiller is identified as Giuffre's lawyers in her lawsuit.
Key Quotes (4)
"hard-fought"Source
— Court in Brown v. Maxwell
(Describing the discovery process in the lawsuit between Giuffre and Maxwell.)
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Quote #1
"extensive"Source
— Court in Brown v. Maxwell
(Describing the discovery process in the lawsuit between Giuffre and Maxwell.)
DOJ-OGR-00002355(2).jpg
Quote #2
"thousands of pages"Source
— Court in Brown v. Maxwell
(Describing the total volume of the court file from the discovery process.)
DOJ-OGR-00002355(2).jpg
Quote #3
"CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement."Source
— Boies Schiller
(A proposed provision for the Protective Order in the Giuffre v. Maxwell case, which was rejected by Maxwell.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,196 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 8 of 23
Giuffre, a public figure required to prove actual malice, had an uphill battle—even she was constrained to acknowledge that many of her public statements were false. Using a time-honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document productions, many responses to interrogatories, and thirty-some depositions, including depositions of Giuffre and Maxwell as well as several third parties. See Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was “hard-fought” and “extensive” and noting that the court file, which includes only some of the documents created during discovery, totals in the “thousands of pages”).
Giuffre sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a stipulated Protective Order. See Ex. A. The Protective Order included a mechanism for one party to challenge another party’s confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before trial, that sole exception to the Protective Order was never triggered.)
Notably, Boies Schiller sought to add a “law enforcement” exception to the Protective Order, doubtless because the firm was eager to enlist the government in its campaign against Maxwell. In particular, Boies Schiller proposed to include a provision stating that “CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement.” Ex. B ¶ 1(a)(4) (emphasis supplied). Maxwell flatly rejected
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