024.pdf
168 KB
Extraction Summary
8
People
7
Organizations
3
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal notice / court filing
File Size:
168 KB
Summary
This document is a legal notice filed by Ghislaine Maxwell's attorneys on December 16, 2016, in the Southern District of Florida regarding a subpoena served on Bradley J. Edwards. Maxwell argues that rulings made by the Southern District of New York on a similar subpoena served on Paul Cassell (another attorney for Virginia Giuffre) should be binding (res judicata) on the Edwards subpoena. The filing includes a table comparing the requests in both subpoenas and the corresponding rulings from the SDNY court, asking the Florida court to issue a consistent order requiring production of certain documents and granting the motion to quash for others.
People (8)
| Name | Role | Context |
|---|---|---|
| Denise D. Riley | Attorney |
Attorney for Ghislaine Maxwell, Riley Law PLLC
|
| Jeffrey S. Pagliuca | Attorney |
Attorney for Ghislaine Maxwell, Haddon, Morgan and Foreman, P.C.
|
| Ghislaine Maxwell | Defendant |
Defendant in underlying case and filer of the notice
|
| Virginia L. Giuffre | Plaintiff |
Plaintiff in underlying case
|
| Bradley J. Edwards | Subpoena Target / Attorney |
Subject of the subpoena duces tecum; attorney for Giuffre
|
| Paul Cassell | Subpoena Target / Attorney |
Attorney for Giuffre who received a similar subpoena
|
| Jack Scarola | Attorney |
Attorney for Bradley J. Edwards
|
| Nicole Simmons | Signatory |
Signed the Certificate of Service
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where this document is filed
|
|
| Riley Law PLLC |
Law firm of Denise D. Riley
|
|
| Haddon, Morgan and Foreman, P.C. |
Law firm of Jeffrey S. Pagliuca
|
|
| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm of Jack Scarola
|
|
| Victims Refuse Silence |
Third party mentioned in footnote regarding document production
|
|
| Southern District of New York |
Court where underlying action is pending and rulings were made
|
|
| District Court for the District of Utah |
Court that transferred the Cassell Motion to Quash to SDNY
|
Timeline (2 events)
2016-08-30
Ruling on the Cassell Motion to Quash issued by the Southern District of New York
Southern District of New York
2017-03
Scheduled trial date for the underlying case (Giuffre v. Maxwell)
Southern District of New York
Locations (3)
| Location | Context |
|---|---|
|
Address of Riley Law PLLC
|
|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of Searcy Denney Scarola Barnhart & Shipley, P.A.
|
Relationships (3)
Document refers to Edwards as one of Plaintiff Virginia Giuffre's attorneys.
Document refers to Cassell as 'one of Plaintiff Virginia Giuffre other attorneys'.
Maxwell served a Subpoena Duces Tecum on Edwards which Edwards moved to quash.
Key Quotes (4)
"Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this notice of her position respecting the Subpoena Duces Tecum to Bradly Edwards and a Related Ruling in the underlying Action"Source
024.pdf
Quote #1
"It is Ms. Maxwell’s position that the rulings made by the Court in the Southern District of New York are res judicata on the Edwards Subpoena with respect to the identical requests in the Cassell Subpoena"Source
024.pdf
Quote #2
"Ms. Maxwell believes that the Court Should issue an Order consistent with the binding determinations of the Court in which the underlying case is pending on identical issues."Source
024.pdf
Quote #3
"Ms. Maxwell does not seek a second production of documents that have already been produced in this matter, including those already produced third parties Mr. Cassell or Victims Refuse Silence."Source
024.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (5,603 characters)
Case 1:17-mc-00025-RWS Document 24 Filed 12/16/16 Page 1 of 5
Denise D. Riley (# 160245)
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
denise@rileylawpl.com
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
denise@rileylawpl.com
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
jpagliuca@hmflaw.com
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
jpagliuca@hmflaw.com
Attorneys for Ghislaine Maxwell
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
In re: SUBPOENA TO BRADLEY J.
EDWARDS
EDWARDS
Underlying case:
VIRGINIA L. GIUFFRE, Plaintiff
v.
GHISLAINE MAXWELL, Defendant
No. 15-cv-07433-RWS (S.D.N.Y.)
NOTICE OF STATUS OF SUBPOENA
DUCES TECUM AND RELATED
RULINGS IN UNDERLYING ACTION
DUCES TECUM AND RELATED
RULINGS IN UNDERLYING ACTION
Case Number 0:16-mc-61262-JG
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this notice of her position respecting
the Subpoena Duces Tecum to Bradly Edwards and a Related Ruling in the underlying Action,
and the Status of outstanding Requests for Production and the Motion to Quash, stating as
follows:
the Subpoena Duces Tecum to Bradly Edwards and a Related Ruling in the underlying Action,
and the Status of outstanding Requests for Production and the Motion to Quash, stating as
follows:
Case 1:17-mc-00025-RWS Document 24 Filed 12/16/16 Page 2 of 5
1. The Court should be advised that in addition to the Subpoena Duces Tecum served on
Bradly Edwards (“Mr. Edwards”) which is the subject of the pending Motion to Quash,
Ms. Maxwell served a similar, although not identical, Subpoena Duces Tecum on one of
Plaintiff Virginia Giuffre other attorneys, Paul Cassell (the “Cassell Subpoena”), Ex. A.
Bradly Edwards (“Mr. Edwards”) which is the subject of the pending Motion to Quash,
Ms. Maxwell served a similar, although not identical, Subpoena Duces Tecum on one of
Plaintiff Virginia Giuffre other attorneys, Paul Cassell (the “Cassell Subpoena”), Ex. A.
2. Mr. Cassell, like Mr. Edwards, moved to quash. The District Court for the District of
Utah transferred the Motion to Quash to the Southern District of New York where the
underlying action is pending.
Utah transferred the Motion to Quash to the Southern District of New York where the
underlying action is pending.
3. The Court presiding over the underlying action in the Southern District of New York
issued a ruling on the Cassell Motion to Quash on August 30, 2016, attached hereto as
Ex. B.
issued a ruling on the Cassell Motion to Quash on August 30, 2016, attached hereto as
Ex. B.
4. Certain of the requests for production in the Cassell Subpoena are identical to the Request
for Production to Mr. Edwards, which is subject to the Motion to Quash in the matter. It
is Ms. Maxwell’s position that the rulings made by the Court in the Southern District of
New York are res judicata on the Edwards Subpoena with respect to the identical
requests in the Cassell Subpoena, and binding Mr. Edwards and Ms. Maxwell. For the
Court’s convenience, the following is a table of the questions that are identical as
between the Edwards Subpoena and the Cassell Subpoena, and the Court’s ruling on each
in the Southern District of New York.
for Production to Mr. Edwards, which is subject to the Motion to Quash in the matter. It
is Ms. Maxwell’s position that the rulings made by the Court in the Southern District of
New York are res judicata on the Edwards Subpoena with respect to the identical
requests in the Cassell Subpoena, and binding Mr. Edwards and Ms. Maxwell. For the
Court’s convenience, the following is a table of the questions that are identical as
between the Edwards Subpoena and the Cassell Subpoena, and the Court’s ruling on each
in the Southern District of New York.
[Table]
Cassell Subpoena – Request No. | Edwards Subpoena Request No. | Southern District of New York Ruling
Request 1 | Request 1 | Motion to Quash Denied – Production Required
Request 2 | Request 2 | Motion to Quash Denied – Production Required
Request 3 | Request 6 | Motion to Quash – Granted
Request 4 | Request 7 | Motion to Quash – Granted (request withdrawn)
Cassell Subpoena – Request No. | Edwards Subpoena Request No. | Southern District of New York Ruling
Request 1 | Request 1 | Motion to Quash Denied – Production Required
Request 2 | Request 2 | Motion to Quash Denied – Production Required
Request 3 | Request 6 | Motion to Quash – Granted
Request 4 | Request 7 | Motion to Quash – Granted (request withdrawn)
Case 1:17-mc-00025-RWS Document 24 Filed 12/16/16 Page 3 of 5
Request 5 | Request 8 | Motion to Quash – Granted (request withdrawn)
Request 6 | Request 9 | Motion to Quash – Granted (request withdrawn)
Request 7 | Request 10 | Motion to Quash Denied – Production Required
Request 8 | Request 11 | Motion to Quash Denied – Production Required
Request 9 | Request 13 | Motion to Quash – Granted
Request 10 | Request 14 | Not Contested – Production Required
Request 11 | Request 15 | Motion to Quash – Granted
Request 12 | Request 16 | Not Contested – Production required
Request 13 | Request 17 | Not Contested – Production Required
Request 14 | Request 18 | Not Contested – Production Required
Request 6 | Request 9 | Motion to Quash – Granted (request withdrawn)
Request 7 | Request 10 | Motion to Quash Denied – Production Required
Request 8 | Request 11 | Motion to Quash Denied – Production Required
Request 9 | Request 13 | Motion to Quash – Granted
Request 10 | Request 14 | Not Contested – Production Required
Request 11 | Request 15 | Motion to Quash – Granted
Request 12 | Request 16 | Not Contested – Production required
Request 13 | Request 17 | Not Contested – Production Required
Request 14 | Request 18 | Not Contested – Production Required
5. Based on the forgoing, Ms. Maxwell believes that the Court Should issue an Order
consistent with the binding determinations of the Court in which the underlying case is
pending on identical issues.
a. Denying the Motion to Quash Request Numbers 1, 2, 10 and 11 and require
Production of documents within 14 days of the Order¹;
b. Granting Motion to Quash 6, 7, 8, 9, 13 and 15; and
c. Requiring Production of the Non-Contested Requests for production, Request
Numbers 14, 16, 17 and 18 within 14 days of the Order.
consistent with the binding determinations of the Court in which the underlying case is
pending on identical issues.
a. Denying the Motion to Quash Request Numbers 1, 2, 10 and 11 and require
Production of documents within 14 days of the Order¹;
b. Granting Motion to Quash 6, 7, 8, 9, 13 and 15; and
c. Requiring Production of the Non-Contested Requests for production, Request
Numbers 14, 16, 17 and 18 within 14 days of the Order.
6. The case remains active and is scheduled for trial in March 2017. Ms. Maxwell requests
that the Court deny the Motion to Quash on the remaining outstanding Requests for
Production, Requests 3, 4, 5, 12, 19 and 20 for the reasons set forth in the Response to the
Motion to Quash.
that the Court deny the Motion to Quash on the remaining outstanding Requests for
Production, Requests 3, 4, 5, 12, 19 and 20 for the reasons set forth in the Response to the
Motion to Quash.
¹ Ms. Maxwell does not seek a second production of documents that have already been produced in this
matter, including those already produced third parties Mr. Cassell or Victims Refuse Silence.
matter, including those already produced third parties Mr. Cassell or Victims Refuse Silence.
Case 1:17-mc-00025-RWS Document 24 Filed 12/16/16 Page 4 of 5
Date: December 16, 2016
Respectfully submitted,
/s/ Denise D. Riley
Denise D. Riley (# 160245)
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
denise@rileylawpl.com
Denise D. Riley (# 160245)
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
denise@rileylawpl.com
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
jpagliuca@hmflaw.com
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
jpagliuca@hmflaw.com
Attorneys for Ghislaine Maxwell
Case 1:17-mc-00025-RWS Document 24 Filed 12/16/16 Page 5 of 5
CERTIFICATE OF SERVICE
I hereby certify that on December 16, 2016, I electronically filed the foregoing Notice of
Status of Subpoena Duces Tecum and Related Rulings in Underlying Action with the Clerk of
Court using the CM/ECF system which sent notification of such filing to the following:
Status of Subpoena Duces Tecum and Related Rulings in Underlying Action with the Clerk of
Court using the CM/ECF system which sent notification of such filing to the following:
Jack Scarola
Searcy Denney Scarola Barnhart &
Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 34409
Phone: 561-686-6300
Fax : 561-383-9451
jsx@searcylaw.com
mep@searcylaw.com
Attorneys for Plaintiff Bradley J.
Edwards
Searcy Denney Scarola Barnhart &
Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 34409
Phone: 561-686-6300
Fax : 561-383-9451
jsx@searcylaw.com
mep@searcylaw.com
Attorneys for Plaintiff Bradley J.
Edwards
/s/ Nicole Simmons
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