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746 KB
Extraction Summary
3
People
3
Organizations
1
Locations
5
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
746 KB
Summary
This legal document describes the contentious discovery phase of a lawsuit between Giuffre and Maxwell. It notes that Giuffre's law firm, Boies Schiller, attempted to turn the suit into a 'proxy prosecution of Epstein' and sought to add a 'law enforcement' exception to a court-mandated Protective Order, which Maxwell rejected. The case ultimately settled before trial, rendering certain provisions of the Protective Order moot.
People (3)
| Name | Role | Context |
|---|---|---|
| Giuffre | Public figure / Litigant |
A party in a lawsuit against Maxwell, described as having an 'uphill battle' and whose lawyers sought to turn the law...
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| Epstein |
Mentioned as the target of a 'proxy prosecution' via the lawsuit involving Giuffre.
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| Maxwell | Litigant |
A party in a lawsuit with Giuffre, subject to discovery of private information, and who rejected a proposed provision...
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Boies Schiller | Law firm |
Identified as the law firm representing Giuffre. They sought to add a 'law enforcement' exception to a Protective Order.
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| government | Government agency |
Mentioned in the context of Boies Schiller being 'eager to enlist the government in its campaign against Maxwell'.
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| law enforcement | Government agency |
Mentioned in a proposed exception to a Protective Order that would allow confidential information to be used for 'inv...
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Timeline (5 events)
Boies Schiller proposed adding a 'law enforcement' exception to the Protective Order, which Maxwell rejected.
Locations (1)
| Location | Context |
|---|---|
|
Cited in a legal reference (Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019)) indicating the jurisdiction of a re...
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Relationships (3)
They were opposing parties in a lawsuit (Brown v. Maxwell) involving 'bitter, hard-fought' discovery.
Giuffre's lawsuit against Maxwell is described as a 'proxy prosecution of Epstein'.
The document refers to 'her lawyers at Boies Schiller'.
Key Quotes (5)
"hard-fought"Source
— Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019)
(Describing the nature of the discovery process in the case.)
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Quote #1
"extensive"Source
— Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019)
(Describing the nature of the discovery process in the case.)
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Quote #2
"thousands of pages"Source
— Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019)
(Describing the total volume of the court file from the discovery process.)
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Quote #3
"law enforcement"Source
— Boies Schiller (proposed)
(The type of exception Boies Schiller sought to add to the Protective Order.)
DOJ-OGR-00002355(3).jpg
Quote #4
"CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement."Source
— Boies Schiller (proposed)
(The specific provision proposed by Boies Schiller to be included in the Protective Order, which was rejected by Maxwell.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,196 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 8 of 23
Giuffre, a public figure required to prove actual malice, had an uphill battle—even she was constrained to acknowledge that many of her public statements were false. Using a time-honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document productions, many responses to interrogatories, and thirty-some depositions, including depositions of Giuffre and Maxwell as well as several third parties. See Brown v. Maxwell, 929 F.3d 41, 46, 51 (2d Cir. 2019) (explaining that discovery was “hard-fought” and “extensive” and noting that the court file, which includes only some of the documents created during discovery, totals in the “thousands of pages”).
Giuffre sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial and sexual matters. Brown, 929 F.3d at 48 n.22. Given the intimate and highly confidential nature of the discovery exchanged between the parties, the district court entered a stipulated Protective Order. See Ex. A. The Protective Order included a mechanism for one party to challenge another party’s confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case settled before trial, that sole exception to the Protective Order was never triggered.)
Notably, Boies Schiller sought to add a “law enforcement” exception to the Protective Order, doubtless because the firm was eager to enlist the government in its campaign against Maxwell. In particular, Boies Schiller proposed to include a provision stating that “CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and any related matter, including but not limited to, investigations by law enforcement.” Ex. B ¶ 1(a)(4) (emphasis supplied). Maxwell flatly rejected
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DOJ-OGR-00002355
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