DOJ-OGR-00008370.jpg

701 KB

Extraction Summary

8
People
1
Organizations
1
Locations
2
Events
4
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 701 KB
Summary

This legal document, dated December 13, 2021, argues that testimony from attorney Robert Glassman is not protected by attorney-client privilege. It focuses on a discrepancy in a witness's ('Jane') memory, where she claimed Mr. Epstein took her to see 'The Lion King' on Broadway in 1994, three years before it premiered. The document details communications between AUSA Rossmiller and Mr. Glassman where the government pointed out the error, but Jane insisted her story was correct.

People (8)

Name Role Context
Alison J. Nathan The Honorable
Addressee of the document.
Robert Glassman
Subject of the document, whose testimony is being discussed. Appears to be an attorney for 'Jane'.
Ms. Maxwell Defendant (implied)
A party in the case who is arguing that attorney-client privilege protects Mr. Glassman from testifying.
Jane Witness (implied)
A person whose story about seeing 'The Lion King' with Mr. Epstein is being scrutinized. Mr. Glassman is her attorney.
Mr. Epstein
Mentioned as the person who allegedly took Jane to see the Broadway production of The Lion King in 1994.
AUSA Rossmiller Assistant United States Attorney
A government attorney who communicated with Mr. Glassman about the discrepancy in Jane's story.
Mr. Edwards
Mentioned in relation to an email exchange with AUSA that showed the government recognized a problem with Jane's story.
Julie Taymor
Mentioned in Jane's account, where Mr. Epstein allegedly bragged about being good friends with her.

Organizations (1)

Name Type Context
government government agency
Mentioned as the entity Mr. Glassman communicated with, and the entity that AUSA Rossmiller represents.

Timeline (2 events)

1994
Jane claimed that Mr. Epstein took her to see the Broadway production of The Lion King.
Broadway
2021-12-03
Ms. Maxwell's side submitted a letter regarding Attorney Glassman's testimony.

Locations (1)

Location Context
Location of the production of 'The Lion King' that Jane claimed to have seen.

Relationships (4)

Robert Glassman professional Jane
Mr. Glassman communicates with the government on Jane's behalf, suggesting an attorney-client relationship.
Mr. Epstein personal Jane
Jane claims Mr. Epstein took her to see a Broadway show.
AUSA Rossmiller professional Robert Glassman
They exchanged emails regarding Jane's testimony for a legal case.
Mr. Epstein personal Julie Taymor
Mr. Epstein allegedly bragged about being 'good friends' with Julie Taymor.

Key Quotes (2)

"help her case"
Source
— Mr. Glassman (What Mr. Glassman allegedly told Jane would happen if she cooperated with the government and testified against Ms. Maxwell.)
DOJ-OGR-00008370.jpg
Quote #1
"Broadway play... Epstein bragged about being good friends with Julie Taymor, and we had amazing first row mezzanine seats they she had apparently given him."
Source
— Jane (Quoted from Jane's response (via email) to AUSA Rossmiller, doubling down on her story that she saw the play, not the movie.)
DOJ-OGR-00008370.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,995 characters)

Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 7 of 9
The Honorable Alison J. Nathan
December 13, 2021
Page 7
Robert Glassman
Ms. Maxwell has already briefed why the attorney-client privilege does not protect Mr. Glassman from having to testify that he told the government that he told Jane it would “help her case” if she cooperated with the government and testified against Ms. Maxwell. Dec. 3, 2021 Maxwell Letter re Attorney Glassman. Mr. Glassman’s statement to Jane was not intended to be confidential and was not in fact maintained as confidential. Id. But even if the privilege did apply, it was waived when Mr. Glassman communicated the statement to the government. Id.
There is a second category of relevant and non-privileged testimony Mr. Glassman has to offer. Jane claimed to remember certain events happening in 1994 because that was the year Mr. Epstein took her to see the Broadway production of The Lion King. As the attached email exchange between AUSA and Mr. Edwards shows, the government quickly recognized a problem with Jane’s story because The Lion King did not premiere on Broadway until 1997. Ex. 1 (3509- 010). AUSA Rossmiller and Mr. Glassman then exchanged emails in which AUSA Rossmiller tried to massage the problem and not-so-subtly invited Jane to change her story to say that she had actually seen The Lion King movie, not the play. But Jane, through Mr. Glassman, doubled down, saying in response to AUSA Rossmiller’s email she saw the Broadway production of The Lion King, not the movie:
Broadway play... Epstein bragged about being good friends with Julie Taymor, and we had amazing first row mezzanine seats they she had apparently given him.
Ex. 1.
There is nothing privileged about this evidence. At the request of AUSA Rossmiller, Mr. Glassman went back to Jane about her The Lion King story. Knowing that the request came from the government, Jane stuck to her story, and Mr. Glassman communicated that response to the
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