015.pdf
21.1 KB
Extraction Summary
9
People
4
Organizations
4
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal motion (motion to seal)
File Size:
21.1 KB
Summary
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
People (9)
| Name | Role | Context |
|---|---|---|
| Bradley J. Edwards | Subpoena respondent / Attorney |
Non-party and attorney for the plaintiff in the Giuffre v. Maxwell action; subject of subpoena.
|
| Virginia L. Giuffre | Plaintiff |
Plaintiff in the underlying case against Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Defendant in the underlying case.
|
| Jack Scarola | Attorney |
Attorney representing Bradley J. Edwards; filed the motion.
|
| Alan Dershowitz | Third Party |
Mentioned in the title of Exhibit 1 regarding a Motion to Intervene.
|
| Rinaldo Rizzo | Deponent |
Mentioned in Exhibit 5; excerpts from his confidential deposition are attached.
|
| Robert Sweet | Judge |
Referred to as Sweet, J.; issued an opinion in SDNY on June 20, 2016.
|
| Laura A. Menninger | Attorney |
Attorney for Ghislaine Maxwell; served with the pleading.
|
| Jeffrey S. Pagliuca | Attorney |
Attorney for Ghislaine Maxwell; served with the pleading.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where this motion is filed.
|
|
| United States District Court Southern District of New York |
Court handling the underlying case (Giuffre v. Maxwell).
|
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| Searcy Denney Scarola Barnhart & Shipley, P.A. |
Law firm representing Bradley J. Edwards.
|
|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing Ghislaine Maxwell.
|
Timeline (2 events)
2016-06-20
Opinion issued by Judge Sweet in Giuffre v. Maxwell (Exhibit 6).
Southern District of New York
Judge Sweet
2016-07-07
Filing of Motion to Seal Bradley J. Edwards' Motion to Quash Subpoena.
Southern District of Florida
Locations (4)
| Location | Context |
|---|---|
|
Location of Searcy Denney Scarola Barnhart & Shipley, P.A.
|
|
|
Location of Haddon, Morgan and Foreman, P.C.
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|
|
Jurisdiction.
|
|
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Jurisdiction.
|
Relationships (3)
Edwards is described as 'attorney for the plaintiff in the Giuffre v. Maxwell action'
Scarola signs as 'Attorney for non-party respondent Bradley J. Edwards'
Rizzo provided a confidential deposition in the Giuffre v. Maxwell case.
Key Quotes (3)
"Subpoena respondent Bradley J. Edwards... hereby files this motion for leave to file materials under seal for his reply in support of his motion to quash."Source
015.pdf
Quote #1
"Exhibit 4 – Excerpts from the Confidential Deposition of Ghislaine Maxwell, which is under seal in the underlying case"Source
015.pdf
Quote #2
"Exhibit 5 - Excerpts from the Confidential Deposition of Rinaldo Rizzo, which is under seal in the underlying case"Source
015.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,819 characters)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
Case No. 0:16-mc-61262-JEM
In re: SUBPOENA TO
BRADLEY J. EDWARDS
BRADLEY J. EDWARDS
Underlying Case:
VIRGINIA L. GIUFFRE,
Plaintiff
v.
GHISLAINE MAXWELL,
Defendant
No. 15-cv-07433-RWS (S.D.N.Y)
______________________________/
______________________________/
MOTION TO SEAL BRADLEY J. EDWARDS’
MOTION TO QUASH SUBPOENA OR, IN THE ALTERNATIVE,
FOR A PROTECTIVE ORDER
MOTION TO QUASH SUBPOENA OR, IN THE ALTERNATIVE,
FOR A PROTECTIVE ORDER
Subpoena respondent Bradley J. Edwards, a non-party and attorney for the plaintiff in the
Giuffre v. Maxwell action, hereby files this motion for leave to file materials under seal for his
reply in support of his motion to quash.
Giuffre v. Maxwell action, hereby files this motion for leave to file materials under seal for his
reply in support of his motion to quash.
In his reply to his motion for to quash subpoena, Edwards attached eight exhibits. Five of
these exhibits contain a document that is under seal in another court, specifically:
these exhibits contain a document that is under seal in another court, specifically:
1. Exhibit 1 – Victims Response to Dershowitz Motion to Intervene, under seal in the
U.S. District Court for the Southern District of Florida;
U.S. District Court for the Southern District of Florida;
Case 1:17-mc-00025-RWS Document 15 Filed 07/07/16 Page 1 of 3
2. Exhibit 3 – Ms. Giuffre’s Motion for Leave to Exceed the Presumptive Ten
Deposition Limit, the salient portions of which (i.e., the portions relied upon in this case) are under
seal in the underlying case in U.S. District Court for the Southern District of New York;
Deposition Limit, the salient portions of which (i.e., the portions relied upon in this case) are under
seal in the underlying case in U.S. District Court for the Southern District of New York;
3. Exhibit 4 – Excerpts from the Confidential Deposition of Ghislaine Maxwell, which
is under seal in the underlying case in U.S. District Court for the Southern District of New York;
is under seal in the underlying case in U.S. District Court for the Southern District of New York;
4. Exhibit 5 - Excerpts from the Confidential Deposition of Rinaldo Rizzo, which is
under seal in the underlying case in U.S. District Court for the Southern District of New York; and
under seal in the underlying case in U.S. District Court for the Southern District of New York; and
5. Exhibit 6 – The Opinion of the U.S. District Court for the Southern District of New
York (Sweet, J.) in Giuffre v. Maxwell, June 20, 2016, which is under seal in the underlying case
in the U.S. District Court for the Southern District of New York.
York (Sweet, J.) in Giuffre v. Maxwell, June 20, 2016, which is under seal in the underlying case
in the U.S. District Court for the Southern District of New York.
In addition, portions of the reply memorandum itself quote from or refer to the sealed
materials. Accordingly, a redacted version of the reply memorandum has been prepared for
inclusion in the public court file, which avoid disclosing the sealed information.
materials. Accordingly, a redacted version of the reply memorandum has been prepared for
inclusion in the public court file, which avoid disclosing the sealed information.
Because the indicated materials are under seal by order of other federal courts, Edwards
seeks leave to file these materials under seal here. Edwards has followed the procedures of the
Southern District of Florida for the handling of sealed materials.
seeks leave to file these materials under seal here. Edwards has followed the procedures of the
Southern District of Florida for the handling of sealed materials.
Opposing counsel has simply filed similar materials in this case under seal without seeking
leave of court. Accordingly, Edwards believes that opposing counsel would have no objection to
his filing of similar materials under seal. Because Edwards believes that a motion is required for
a sealed filing, he proceeds by way of motion to this Court.
leave of court. Accordingly, Edwards believes that opposing counsel would have no objection to
his filing of similar materials under seal. Because Edwards believes that a motion is required for
a sealed filing, he proceeds by way of motion to this Court.
Case 1:17-mc-00025-RWS Document 15 Filed 07/07/16 Page 2 of 3
CONCLUSION
For the forgoing reasons, Edwards respectfully requests that this Court allow him to submit
materials under seal in his reply memorandum supporting his motion to quash.
materials under seal in his reply memorandum supporting his motion to quash.
Dated: July 7, 2016
Respectfully Submitted,
/s/ Jack Scarola
Jack Scarola
Florida Bar No.: 169440
Attorney E-Mail(s): jsx@searcylaw.com and
mep@searcylaw.com
Primary E-Mail: _scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Jack Scarola
Florida Bar No.: 169440
Attorney E-Mail(s): jsx@searcylaw.com and
mep@searcylaw.com
Primary E-Mail: _scarolateam@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorney for non-party respondent
Bradley J. Edwards
Bradley J. Edwards
CERTIFICATE OF SERVICE
I certify that on July 7, 2016, I electrically served the foregoing pleading via the Court’s
CM/ECF filing system on:
CM/ECF filing system on:
Laura A. Menninger
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: (303) 831-7364
Fax: (303) 832-2628
lmenninger@hmflaw.com
Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: (303) 831-7364
Fax: (303) 832-2628
lmenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
Case 1:17-mc-00025-RWS Document 15 Filed 07/07/16 Page 3 of 3
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