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558 KB
Extraction Summary
4
People
2
Organizations
0
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (criminal case)
File Size:
558 KB
Summary
This document is page 15 of a legal filing (Document 134) from the criminal case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on February 4, 2021. The text argues that the government colluded with a redacted third party (likely civil plaintiffs) starting in 2016 to engineer perjury charges against Maxwell. It contrasts two judicial rulings: one granting a government ex parte request and another rejecting an identical request in a different civil case, characterizing the government's actions as an attempt to deprive Maxwell of due process.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case; defense argues she was deprived of notice and opportunity to be heard regarding unseali...
|
| The Government | Prosecution |
Accused by the defense of collusion with civil litigants and attempting to deprive Maxwell of rights via ex parte req...
|
| [REDACTED] | Civil Litigant/Counsel (Implied) |
An entity or person accused of 'fomenting' the investigation and colluding with the government in 2016.
|
| [REDACTED] | Judges (Implied) |
Two different judges mentioned; one granted a government request, another rejected an identical request.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States Attorney’s Office |
Mentioned in footnote 6 regarding meetings in 2016 with the redacted party.
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR).
|
Timeline (2 events)
2016
Meetings between a redacted party and the US Attorney's Office where sealed materials may have been shared.
Unknown
[REDACTED]
US Attorney's Office
Relationships (1)
Defense claims evidence of collusion tracing to early 2016 designed to charge Maxwell with perjury.
Key Quotes (4)
"Contrary to the government’s misrepresentations, [REDACTED] did foment the investigation (or at least it tried to)."Source
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Quote #1
"And the evidence of “collusion” between the government and [REDACTED] was ample, tracing to at least early 2016 and precisely designed to have Maxwell charged with perjury."Source
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Quote #2
"[REDACTED] recognized the government’s conduct for what it was: an attempt to deprive Maxwell of notice and an opportunity to be heard."Source
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Quote #3
"the bare minimum that is required here is an evidentiary hearing to probe the extent to which [REDACTED] “colluded,” in a Chemical Bank sense, with the prosecutor’s office."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,513 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 15 of 23
Contrary to the government’s misrepresentations, [REDACTED] did foment the
investigation (or at least it tried to). And the evidence of “collusion” between the government
and [REDACTED] was ample, tracing to at least early 2016 and precisely designed to have
Maxwell charged with perjury.6 [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
investigation (or at least it tried to). And the evidence of “collusion” between the government
and [REDACTED] was ample, tracing to at least early 2016 and precisely designed to have
Maxwell charged with perjury.6 [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
E. [REDACTED] Separately Rejects An Identical Gambit By The
Government
Government
Around the same time that [REDACTED] granted the government’s ex parte request,
[REDACTED] rejected an identical request from the government in a different civil
case, [REDACTED] recognized the
government’s conduct for what it was: an attempt to deprive Maxwell of notice and an
opportunity to be heard. Ex. H. Indeed, [REDACTED] rebuffed the government even after it
alerted her to [REDACTED] order. Ex. I. As [REDACTED] found, [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED] Ex. H, p
6. [REDACTED]—that [REDACTED]
[REDACTED] was all too eager for the government to investigate and prosecute Maxwell:
[REDACTED] rejected an identical request from the government in a different civil
case, [REDACTED] recognized the
government’s conduct for what it was: an attempt to deprive Maxwell of notice and an
opportunity to be heard. Ex. H. Indeed, [REDACTED] rebuffed the government even after it
alerted her to [REDACTED] order. Ex. I. As [REDACTED] found, [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED] Ex. H, p
6. [REDACTED]—that [REDACTED]
[REDACTED] was all too eager for the government to investigate and prosecute Maxwell:
_________________________
6 Maxwell has not yet been provided discovery of whether [REDACTED] shared actual sealed
materials or the contents of sealed materials during its meetings with the United States Attorney’s Office
in 2016. As noted below, the bare minimum that is required here is an evidentiary hearing to probe the
extent to which [REDACTED] “colluded,” in a Chemical Bank sense, with the prosecutor’s office.
6 Maxwell has not yet been provided discovery of whether [REDACTED] shared actual sealed
materials or the contents of sealed materials during its meetings with the United States Attorney’s Office
in 2016. As noted below, the bare minimum that is required here is an evidentiary hearing to probe the
extent to which [REDACTED] “colluded,” in a Chemical Bank sense, with the prosecutor’s office.
10
DOJ-OGR-00002362
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