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564 KB
Extraction Summary
5
People
3
Organizations
0
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Court transcript
File Size:
564 KB
Summary
This document is a page from a court transcript (Case 1:20-cr-00330-AJN, Ghislaine Maxwell trial) filed on August 10, 2022. Defense attorney Mr. Pagliuca argues regarding the admissibility of communications between witnesses' lawyers (specifically mentioning Mr. Scarola) and the government, citing an email where Scarola suggested ten interview topics for a witness named Carolyn. The discussion centers on whether these communications and proffers are privileged or if they can be used as evidence regarding the 'cultivating of stories'.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Sternheim | Attorney |
Mentioned in the header 'Opening - Ms. Sternheim'
|
| The Court | Judge |
Presiding over the hearing, questioning Mr. Pagliuca
|
| Mr. Pagliuca | Attorney |
Speaking to the court regarding witness testimony, proffers, and emails
|
| Mr. Scarola | Attorney |
Sent an email to the government suggesting ten topics for an interview with Carolyn
|
| Carolyn | Witness/Subject |
Subject of an interview for which Mr. Scarola suggested topics
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution/Department of Justice, recipient of emails and participant in proffers
|
|
| Southern District Reporters, P.C. |
Court reporting agency listed in footer
|
|
| DOJ-OGR |
Department of Justice - Office of Government Relations (indicated by footer stamp)
|
Timeline (1 events)
Relationships (2)
Scarola suggested topics for Carolyn's interview to the government.
Dialogue in transcript.
Key Quotes (4)
"There's an email from Mr. Scarola to the government in which Mr. Scarola suggests ten topics for the interview with Carolyn."Source
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Quote #1
"The lawyers are in proffers, your Honor, and the witness is in the proffer."Source
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Quote #2
"Those are not privileged conversations."Source
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Quote #3
"Not unless we brief it and you give us permission to do that."Source
DOJ-OGR-00016165.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,405 characters)
Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 55 of 106 59
LBTVMAX3 Opening - Ms. Sternheim
LBTVMAX3 Opening - Ms. Sternheim
1 THE COURT: So tell me what you're going to do.
2 You're going to call -- so a witness will testify, and then
3 you're going to call that witness's attorney. What is it that
4 you're going to do? What evidence are you going to --
5 MR. PAGLIUCA: The lawyers are in proffers, your
6 Honor, and the witness is in the proffer. The witness can talk
7 about what the lawyer said to the government in the proffer.
8 The lawyers have emails to the government lawyers about what
9 their clients will or won't say. There's an email from
10 Mr. Scarola to the government in which Mr. Scarola suggests ten
11 topics for the interview with Carolyn. Those are not
12 privileged conversations.
13 THE COURT: Sorry. Just to clarify, you're saying
14 this is not what you just said, the cultivating of the stories
15 by these lawyers; you do not intend to get that by calling any
16 of these lawyers as witnesses.
17 MR. PAGLIUCA: Not unless we brief it and you give us
18 permission to do that.
19 THE COURT: But instead, it's based on communications
20 between the lawyers and the government?
21 MR. PAGLIUCA: Correct.
22 THE COURT: And email.
23 MR. PAGLIUCA: And in proffers.
24 THE COURT: And in proffers in which the government
25 was present.
2 You're going to call -- so a witness will testify, and then
3 you're going to call that witness's attorney. What is it that
4 you're going to do? What evidence are you going to --
5 MR. PAGLIUCA: The lawyers are in proffers, your
6 Honor, and the witness is in the proffer. The witness can talk
7 about what the lawyer said to the government in the proffer.
8 The lawyers have emails to the government lawyers about what
9 their clients will or won't say. There's an email from
10 Mr. Scarola to the government in which Mr. Scarola suggests ten
11 topics for the interview with Carolyn. Those are not
12 privileged conversations.
13 THE COURT: Sorry. Just to clarify, you're saying
14 this is not what you just said, the cultivating of the stories
15 by these lawyers; you do not intend to get that by calling any
16 of these lawyers as witnesses.
17 MR. PAGLIUCA: Not unless we brief it and you give us
18 permission to do that.
19 THE COURT: But instead, it's based on communications
20 between the lawyers and the government?
21 MR. PAGLIUCA: Correct.
22 THE COURT: And email.
23 MR. PAGLIUCA: And in proffers.
24 THE COURT: And in proffers in which the government
25 was present.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00016165
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