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533 KB
Extraction Summary
3
People
2
Organizations
0
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / appellate brief
File Size:
533 KB
Summary
This is a page from a legal filing (Case 20-3061) dated September 24, 2020. The text argues that Judge Preska erred by ignoring Ghislaine Maxwell's 'reliance argument.' It states that Maxwell did not plead the Fifth Amendment during her depositions because she relied on a civil protective order and the *Martindell* precedent, which protects witness testimony from being used by the Government for criminal investigations or perjury charges.
People (3)
| Name | Role | Context |
|---|---|---|
| Judge Preska | Judge |
Accused of erring by failing to acknowledge Ms. Maxwell's reliance argument.
|
| Ghislaine Maxwell | Defendant / Appellant |
Declined to invoke Fifth Amendment privilege during depositions relying on a protective order.
|
| Virginia Giuffre | Plaintiff / Appellee |
Mentioned in case citation 'Giuffre v. Maxwell'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Referenced in the context of criminal investigations and inspecting protected testimony.
|
|
| Department of Justice (DOJ) |
Implied by Bates stamp 'DOJ-OGR'.
|
Timeline (2 events)
Unknown (past)
Ms. Maxwell's two depositions where she declined to invoke the Fifth Amendment.
Unknown
Relationships (2)
Brief argues Judge Preska erred in a ruling affecting Maxwell.
Case citation Giuffre v. Maxwell.
Key Quotes (3)
"Judge Preska erred failing even to acknowledge or address Ms. Maxwell’s reliance argument."Source
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Quote #1
"Ms. Maxwell declined to invoke her Fifth Amendment privilege against self-incrimination during her two depositions."Source
DOJ-OGR-00019436.jpg
Quote #2
"a witness should be entitled to rely upon the enforceability of a protective order against any third parties, including the Government"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,087 characters)
Case 20-3061, Document 60, 09/24/2020, 2938278, Page37 of 58
[REDACTED]
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Finally, [REDACTED]
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[REDACTED]
And it shows that Judge Preska erred failing even to acknowledge or address Ms.
Maxwell’s reliance argument. Giuffre v. Maxwell, Case No. 20-2413, OB, p 24. Ms.
Maxwell declined to invoke her Fifth Amendment privilege against self-
incrimination during her two depositions. She made that decision relying on the
civil protective order and this Court’s decision in Martindell, which holds that
Maxwell’s reliance argument. Giuffre v. Maxwell, Case No. 20-2413, OB, p 24. Ms.
Maxwell declined to invoke her Fifth Amendment privilege against self-
incrimination during her two depositions. She made that decision relying on the
civil protective order and this Court’s decision in Martindell, which holds that
absent a showing of improvidence in the grant of a Rule 26(c)
protective order or some extraordinary circumstance or compelling
need, none of which appear here, a witness should be entitled to rely
upon the enforceability of a protective order against any third parties,
including the Government, and that such an order should not be
vacated or modified merely to accommodate the Government’s desire
to inspect protected testimony for possible use in a criminal
investigation, either as evidence or as the subject of a possible perjury
charge.
protective order or some extraordinary circumstance or compelling
need, none of which appear here, a witness should be entitled to rely
upon the enforceability of a protective order against any third parties,
including the Government, and that such an order should not be
vacated or modified merely to accommodate the Government’s desire
to inspect protected testimony for possible use in a criminal
investigation, either as evidence or as the subject of a possible perjury
charge.
32
DOJ-OGR-00019436
DOJ-OGR-00019436
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