DOJ-OGR-00001863.jpg
964 KB
Extraction Summary
6
People
4
Organizations
1
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
964 KB
Summary
This document is page 2 of a legal filing to Judge Alison J. Nathan, dated November 25, 2020, arguing for the sealing of certain court documents. The filing cites extreme harassment and violent threats against Ms. Maxwell on social media as a reason to protect the identities of sureties. It also mentions a confidential financial report on Ms. Maxwell prepared by Macalvins Limited and discusses legal precedents regarding the presumption of public access to court records.
People (6)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Recipient of the letter/legal filing.
|
| Ms. Maxwell | Subject of legal case |
Referenced as the subject of media scrutiny, threats, a financial report, and legal proceedings.
|
| Epstein |
Mentioned in a social media post accusing Ms. Maxwell of sex trafficking for him.
|
|
| Lugosch | Party in a cited legal case |
Mentioned in the case citation 'Lugosch v. Pyramid Co. of Onandaga'.
|
| Wey | Party in a cited legal case |
Mentioned in the case citation 'Unites States v. Wey'.
|
| Brown | Party in a cited legal case |
Mentioned in the case citation 'Brown v. Maxwell'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Macalvins Limited | accounting firm |
Prepared a financial report summarizing Ms. Maxwell's financial condition from 2015-2020.
|
| ManchesterMAPD | government agency |
Mentioned in a social media post, likely referring to the Manchester, MA Police Department, being questioned about Ms...
|
| Second Circuit | government agency |
Referenced as a court that has recognized a presumption of public access to documents.
|
| Pyramid Co. of Onandaga | company |
Mentioned in the case citation 'Lugosch v. Pyramid Co. of Onandaga'.
|
Timeline (2 events)
2015-2020
A financial report was prepared by Macalvins Limited summarizing Ms. Maxwell's financial condition during this period.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a social media post as a possible location of Ms. Maxwell.
|
Relationships (2)
A social media post quoted in the document accuses Ms. Maxwell of having '#SexTrafficked young girls for #Epstein'.
The document states that the accounting firm Macalvins Limited prepared a financial report for Ms. Maxwell.
Key Quotes (6)
"they need to get this bitch n string her up by her neck . . . f*cking monster . . . #GhislaineMaxwell."Source
— Social media user
(Provided as a sample of social media posts threatening Ms. Maxwell.)
DOJ-OGR-00001863.jpg
Quote #1
"I hope someone finds her and kills her. That would be justice. Obviously her lawyers know’s where she is, someone should stick them up to batteries untill we find out where she is."Source
— Social media user
(Provided as a sample of social media posts threatening Ms. Maxwell.)
DOJ-OGR-00001863.jpg
Quote #2
"SHE’S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn’t she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE! #SleezyLeach She is CLOSE ENOUGH to me, I could grab her myself!"Source
— Social media user
(Provided as a sample of social media posts threatening Ms. Maxwell.)
DOJ-OGR-00001863.jpg
Quote #3
"a court may order that a filing be made under seal without redaction. The court may later unseal the filing or order the person who made the filing to file a redacted version for the public record."Source
— Fed. R. Crim. P. 49.1(d)
(Quoted as legal justification for filing documents under seal.)
DOJ-OGR-00001863.jpg
Quote #4
"countervailing factors"Source
— Lugosch v. Pyramid Co. of Onandaga
(A legal standard from case law that permits filing documents under seal.)
DOJ-OGR-00001863.jpg
Quote #5
"ancillary to the court’s core role in adjudicating a case"Source
— Brown v. Maxwell
(A legal standard from case law describing documents that have a lower presumption of public access.)
DOJ-OGR-00001863.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (3,065 characters)
Case 1:20-cr-00330-AJN Document 90 Filed 12/07/20 Page 2 of 4
The Honorable Alison J. Nathan
November 25, 2020
Page 2
November 25, 2020
Page 2
harassment of the sureties and other third parties, including minor children. They are legitimately afraid that if their identities become public, they will be subjected to the same relentless media scrutiny and threats that Ms. Maxwell has experienced for more than a year, like the following sample of social media posts:
“they need to get this bitch n string her up by her neck . . . f*cking monster . . .
#GhislaineMaxwell.”
#GhislaineMaxwell.”
“I hope someone finds her and kills her. That would be justice. Obviously her
lawyers know’s where she is, someone should stick them up to batteries untill we
find out where she is.”
lawyers know’s where she is, someone should stick them up to batteries untill we
find out where she is.”
“SHE’S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who
#SexTrafficked young girls for #Epstein ?!?! Why the hell isn’t she being brought in
for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE!
#SleezyLeach She is CLOSE ENOUGH to me, I could grab her myself!”
#SexTrafficked young girls for #Epstein ?!?! Why the hell isn’t she being brought in
for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HERE!
#SleezyLeach She is CLOSE ENOUGH to me, I could grab her myself!”
• A financial report, prepared by the accounting firm Macalvins Limited, that provides a summary of Ms. Maxwell’s financial condition from 2015-2020 and discloses all of her assets, all assets held in trust, and assets held by other family members.
• A discussion and analysis of certain materials produced by the government in discovery marked “Confidential” and their impact on the government’s case against Ms. Maxwell, which must be filed under seal pursuant to the terms of the Protective Order in this case (Dkt. 36).
Fed. R. Crim. P. 49.1(d) provides that “a court may order that a filing be made under seal without redaction. The court may later unseal the filing or order the person who made the filing to file a redacted version for the public record.” While the Second Circuit has recognized a presumption of access under both common law and the First Amendment, it is appropriate to permit the filing of documents under seal if “countervailing factors” in the common law framework or “higher values” in the First Amendment framework so demand. Lugosch v. Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits and finding that privacy interests “outweigh any public interest in disclosure, whether derived from the First Amendment or the common-law right of access”).
Moreover, a lower presumption of public access applies to documents submitted in connection with powers that are “ancillary to the court’s core role in adjudicating a case” than to “material introduced at trial, or in connection with dispositive motions.” Brown v. Maxwell, 929 F.3d 41, 49-50 (2d Cir. 2019) (applying lower presumption to documents submitted in connection with discovery and evidentiary motions than to summary judgment filings). Thus, a lower presumption of public access attaches the parties’ pretrial bail submissions than to exhibits introduced at trial or in connection with a motion to dismiss.
DOJ-OGR-00001863
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document