DOJ-OGR-00008371.jpg
674 KB
Extraction Summary
5
People
3
Organizations
0
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
674 KB
Summary
This legal document, part of a court filing, argues that certain communications related to a claimant named 'Jane' are not protected by attorney-client privilege. The argument is based on her representative, Mr. Glassman, sharing her statements and settlement demands with third parties, including the government, the EVCP, and Ms. Maxwell's counsel. The document details specific financial demands, such as a $25 million demand and a $5 million offer, to demonstrate that these communications were not confidential.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Addressed at the top of the document.
|
| Jane | Claimant |
A person whose statement and settlement negotiations are the subject of the document's legal argument regarding privi...
|
| Mr. Glassman | Representative/Counsel for Jane |
An individual who communicated with the government, the EVCP, and Ms. Maxwell's counsel on behalf of Jane.
|
| Ms. Maxwell | Party to the case |
A person from whom Mr. Glassman demanded $25 million for Jane. The document mentions her constitutional rights.
|
| AUSA Rossmiller | Assistant United States Attorney |
An individual whose communications with Mr. Glassman are argued to be not privileged.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| EVCP | Victim Compensation Program (implied) |
An entity that made a $5 million settlement offer to Jane and with whom Mr. Glassman negotiated.
|
| Steinhardt Partners | company |
Mentioned in a legal citation (Steinhardt Partners, 9 F.3d at 236).
|
| U.S. Government | government agency |
Mentioned as the recipient of Jane's statement from Mr. Glassman.
|
Timeline (2 events)
A series of settlement negotiations involving Jane's claim, including an offer from the EVCP and demands from Mr. Glassman to the EVCP and Ms. Maxwell.
Relationships (3)
Mr. Glassman acted on Jane's behalf in settlement negotiations with the EVCP and Ms. Maxwell, demanding money for her claim. The document discusses whether their communications are protected by attorney-client privilege.
Mr. Glassman demanded $25 million from Ms. Maxwell on behalf of Jane.
They had exchanges that are being argued as not privileged in the context of the legal case.
Key Quotes (3)
"intended to be . . . kept confidential."Source
— Erie, 473 F.3d at 419 (cited source)
(Used to argue that Jane's statement is not privileged because it was not intended to be kept confidential.)
DOJ-OGR-00008371.jpg
Quote #1
"is a sophisticated claimant who knows the value of her claim is worth a lot more than $5 million."Source
— Mr. Glassman
(A statement Mr. Glassman made to the EVCP in response to their $5 million settlement offer for Jane.)
DOJ-OGR-00008371.jpg
Quote #2
"communication[s] between client and counsel."Source
— Erie, 473 F.3d at 419 (cited source)
(Used to argue that exchanges between AUSA Rossmiller and Mr. Glassman are not privileged.)
DOJ-OGR-00008371.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,947 characters)
Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 8 of 9
The Honorable Alison J. Nathan
December 13, 2021
Page 8
December 13, 2021
Page 8
government. Jane’s statement is not privileged because it was not “intended to be . . . kept confidential.” See Erie, 473 F.3d at 419. And any privilege that may have existed was waived when Mr. Glassman shared Jane’s statement with the government. See Fed. R. Evid. 502(a); Steinhardt Partners, 9 F.3d at 236; 1 McCormick on Evid., § 93.
There is a third category of relevant communications. During cross-examination, Jane denied knowing that after the EVCP made its $5 million offer to settle, Mr. Glassman went back to the EVCP on her behalf to seek more money. TR at 558:8-17. In fact, Mr. Glassman did exactly that. He originally demanded $25 million for Jane from Ms. Maxwell. Jane then filed a claim with the EVCP, which offered $5 million. Mr. Glassman replied to the EVCP that Jane “is a sophisticated claimant who knows the value of her claim is worth a lot more than $5 million.” Mr. Glassman then demanded a settlement in the eight figures. Because Mr. Glassman communicated these demands to a third party, the first demand to Ms. Maxwell’s counsel and the second to the EVCP, and because these communications were not between Mr. Glassman and his client, the exchanges are not protected by the attorney-client privilege and, even if they were, any privilege was waived.
Finally, there can be no argument that AUSA Rossmiller’s statements to Mr. Glassman, and Mr. Glassman’s statements in response, which do not repeat or refer to statements by Jane, are not privileged. The exchanges between AUSA Rossmiller and Mr. Glassman are not “communication[s] between client and counsel.” See Erie, 473 F.3d at 419.
* * *
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
DOJ-OGR-00008371
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document