DOJ-OGR-00008209.jpg
558 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
558 KB
Summary
This legal document, dated December 3, 2021, is a filing addressed to Judge Alison J. Nathan. The author argues that Ms. Maxwell has a constitutional right to call Mr. Glassman as a witness to question him about advice he gave to a person named Jane regarding cooperation with the government. The argument posits that any attorney-client privilege was waived when Mr. Glassman disclosed this advice, and that this testimony is crucial for Ms. Maxwell's defense.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The document is addressed to The Honorable Alison J. Nathan.
|
| Mr. Glassman |
A person the parties wish to examine regarding his communications with the government and advice he gave to Jane.
|
|
| Jane |
An individual who received advice from Mr. Glassman about cooperating with the government.
|
|
| Ms. Maxwell | Defendant/Party in a legal case |
A party in the case who asserts a constitutional right to call Mr. Glassman as a witness to inquire about advice he g...
|
| Wigmore | Legal authority |
Cited as a legal authority on the concept of waiver of privilege.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Steinhardt Partners, L.P. | company |
Mentioned in a case citation, 'In re Steinhardt Partners, L.P., 9 F.3d 230, (2d Cir. 1993)'.
|
| The Court | government agency |
The judicial body being addressed, urged to hold a hearing if it has any doubt.
|
Timeline (2 events)
A proposed brief hearing, outside the presence of the jury, to examine Mr. Glassman about his communications.
Court
Mr. Glassman
the parties
A government investigation is mentioned in the context of a party deciding that the benefits of participation outweigh confidentiality.
the government
Relationships (3)
The document discusses Mr. Glassman giving 'his advice to Jane,' implying an attorney-client or advisory relationship.
Ms. Maxwell seeks to call Mr. Glassman as a witness in her defense.
The document discusses Jane potentially 'testifying against Ms. Maxwell'.
Key Quotes (3)
"necessarily decides that the benefits of participation [in the government investigation] outweigh the benefits of confidentiality"Source
— In re Steinhardt Partners, L.P.
(Quoted from a legal precedent to argue that disclosing privileged information to the government constitutes a waiver.)
DOJ-OGR-00008209.jpg
Quote #1
"Waiver may be found, as Wigmore points out, not merely from words or conduct expressing an intention to relinquish a known right, but also from conduct such as partial disclosure which would make it unfair for the client to invoke the privilege thereafter."Source
— 1 McCormick On Evid., § 93
(A quote from a legal treatise explaining how waiver of privilege can occur through conduct like partial disclosure.)
DOJ-OGR-00008209.jpg
Quote #2
"help her case"Source
— Mr. Glassman
(The alleged advice Mr. Glassman gave to Jane regarding cooperating with the government and testifying against Ms. Maxwell.)
DOJ-OGR-00008209.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,522 characters)
Case 1:20-cr-00330-PAE Document 521 Filed 12/03/21 Page 4 of 5
The Honorable Alison J. Nathan
December 3, 2021
Page 4
December 3, 2021
Page 4
protection . . . .” See Fed. R. Evid. 502(a) (defining the limits of such a waiver as to undisclosed or inadvertently disclosed information); In re Steinhardt Partners, L.P., 9 F.3d 230, (2d Cir. 1993) (when a party voluntarily discloses otherwise privileged information to the government, she “necessarily decides that the benefits of participation [in the government investigation] outweigh the benefits of confidentiality”); 1 McCormick On Evid., § 93 (“Waiver may be found, as Wigmore points out, not merely from words or conduct expressing an intention to relinquish a known right, but also from conduct such as partial disclosure which would make it unfair for the client to invoke the privilege thereafter.”).
If the Court has any doubt about this issue, it should hold a brief hearing, outside the presence of the jury, in which the parties can examine Mr. Glassman about the circumstances of his communications with the government in which he revealed his advice to Jane.
Ms. Maxwell has a constitutional right to compulsory process and to present a defense. U.S. Const. amends. V, VI. Because the attorney-client privilege does not preclude her from asking Mr. Glassman whether he told Jane that cooperating with the government and testifying against Ms. Maxwell would “help her case,” Ms. Maxwell has a constitutional right to call him as a witness and make this inquiry.
DOJ-OGR-00008209
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document