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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, part of case 1:20-cr-00330-AJN filed on February 4, 2021, discusses the terms of a Protective Order concerning confidential materials. It describes how Maxwell relied on this order to testify in her April and July 2016 depositions and a subsequent motion by Giuffre to compel her to answer further questions. The document includes assurances from the law firm Boies Schiller that any answers would remain confidential under the order.
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Boies Schiller | Law firm |
Mentioned as having assured the district court about the appropriateness and confidentiality of questions for Maxwell.
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| the government | Government agency |
Mentioned in a footnote as a potential recipient of leaked confidential material.
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Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
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The court where Boies Schiller provided assurances regarding a motion.
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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
(A direct quote from paragraph 12 of the Protective Order detailing the handling of confidential materials after the case concludes.)
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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 by the law firm to the district court in support of Giuffre's 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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