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893 KB
Extraction Summary
4
People
2
Organizations
0
Locations
3
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
893 KB
Summary
This legal document is a letter to Judge Alison J. Nathan, dated November 30, 2020, arguing for the redaction of the identities of individuals supporting Ms. Maxwell's bail application. The letter contends that public disclosure would violate their privacy and expose them to significant personal and physical danger, citing stalking by the tabloid press, physical threats, and the intense public opprobrium surrounding the case. It references legal precedent from United States v. Amodeo to support the court's power to protect innocent third parties from public scandal.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The document is addressed to The Honorable Alison J. Nathan.
|
| Ms. Maxwell | Defendant |
The subject of the legal filing, who is requesting redactions to protect her bail sureties and is the subject of a re...
|
| Epstein |
Mentioned in a footnote regarding Ms. Maxwell's alleged role in his sex trafficking crimes.
|
|
| Esther Salas | Judge |
Mentioned in a footnote regarding the tragic death of her son as an example of violence against innocent third parties.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Mentioned as conceding that certain information should be redacted and proposing the removal or redaction of names.
|
| tabloid press | media |
Mentioned as having physically stalked people close to Ms. Maxwell.
|
Timeline (3 events)
2020-11-30
This document, a letter to Judge Alison J. Nathan, was written to argue for the redaction of information identifying Ms. Maxwell's bail sureties.
Ms. Maxwell's legal team
Alison J. Nathan
Ms. Maxwell has a renewed bail application, which is being supported by several individuals (sureties/co-signers) whose identities are sought to be protected.
People close to Ms. Maxwell have been physically stalked by the tabloid press and have been the target of repeated physical threats.
People close to Ms. Maxwell
members of the tabloid press
Relationships (2)
The document discusses individuals who want to support Ms. Maxwell's renewed bail application, referring to them as a 'proposed co-signer' and 'sureties'.
A footnote mentions Ms. Maxwell's 'alleged role in Epstein’s sex trafficking crimes'.
Key Quotes (1)
"[t]he privacy interests of innocent third parties . . . should weigh heavily in a court’s balancing equation. . . . [C]ourts have the power to insure that their records are not used to gratify private spite or promote public scandal[.]"Source
— United States v. Amodeo, 71 F.3d 1044, 1050-51 (2d Cir. 1995)
(Cited as legal precedent to support the argument for redacting the identities of sureties to protect their privacy.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,852 characters)
Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 2 of 4
The Honorable Alison J. Nathan
November 30, 2020
Page 2
November 30, 2020
Page 2
With regard to the November 25th Letter, Ms. Maxwell requests redaction of three sentences. The first sentence must be redacted because it contains information that will identify a proposed co-signer. The government, itself, concedes that such information should be redacted. (See November 25th Letter at 3). The reference in this sentence to [REDACTED]
Even assuming, arguendo, that there is some minimal public interest in knowing the identity of a particular surety, it is vastly outweighed by the significant privacy concerns in this case. See United States v. Amodeo, 71 F.3d 1044, 1050-51 (2d Cir. 1995) (“[t]he privacy interests of innocent third parties . . . should weigh heavily in a court’s balancing equation. . . . [C]ourts have the power to insure that their records are not used to gratify private spite or promote public scandal[.]”).¹
Similarly, redaction of the second and third sentences, like the first, is necessary to protect the privacy and safety of people who have suffered, or legitimately fear they will suffer, terrible personal and professional consequences for having been linked to Ms. Maxwell. People close to Ms. Maxwell have been physically stalked by members of the tabloid press and have had paparazzi jump out of bushes and in front of their cars to snap pictures of them. [REDACTED]
¹ [REDACTED] And several have been the target of repeated physical threats. Many of the people who want to support Ms. Maxwell’s renewed bail application are older and do not have the financial means to hire a personal security detail to protect themselves. Nor should they have to. They are all people of good character who are simply trying to support Ms. Maxwell’s constitutional right to seek release on bail. They should be given appropriate protections so that they can step forward without having their lives upended or, worse, destroyed.²
The November 25th Letter, as submitted, intentionally avoided naming these individuals for this very reason. But removing or redacting their names, as the government proposes, is not enough. This case has generated so much media attention and public opprobrium that public [REDACTED]
² Given the sensitive subject matter of this case, the sureties have legitimate fears for their safety if they are publicly identified. Numerous social media posts have advocated killing Ms. Maxwell as a perverse form of “justice” for her alleged role in Epstein’s sex trafficking crimes. As we have all been recently reminded with the tragic case of the death of Judge Esther Salas’s son, there are people who are capable of committing horrible acts of violence—even against innocent third parties—by convincing themselves that their actions are justified.
DOJ-OGR-00001856
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