DOJ-OGR-00008376.jpg
636 KB
Extraction Summary
6
People
4
Organizations
1
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (legal memorandum/motion response)
File Size:
636 KB
Summary
This document is page 3 of a court filing (Document 545) in the Ghislaine Maxwell trial (Case 1:20-cr-00330-PAE), filed on December 15, 2021. The text argues against the defendant's motion to call three attorneys for victims (Jack Scarola, Brad Edwards, and Robert Glassman) as witnesses, stating such testimony would be irrelevant, duplicative, or improper impeachment. Specifically regarding Jack Scarola, the document notes he represented victim 'Carolyn' in a 2008 lawsuit and before the Epstein Victims Compensation Program, facts which Carolyn already admitted during cross-examination.
People (6)
| Name | Role | Context |
|---|---|---|
| The defendant | Defendant |
Seeks to call attorneys for victims as witnesses (Implied to be Ghislaine Maxwell based on case number 1:20-cr-00330)
|
| Jack Scarola | Attorney |
Attorney for victim Carolyn; defendant seeks to call him to testify
|
| Brad Edwards | Attorney |
Attorney for victims; defendant seeks to call him to testify
|
| Robert Glassman | Attorney |
Attorney for victims; defendant seeks to call him to testify
|
| Carolyn | Victim/Witness |
Client of Jack Scarola; testified on cross-examination regarding her 2008 lawsuit and contact with government
|
| Mr. Danchuck | Representative |
Representative for Carolyn who responded to the Government in July 2020
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Government |
Prosecution/DOJ
|
|
| Epstein Victims Compensation Program |
Fund for compensating victims, before which Scarola represented Carolyn
|
|
| ABA |
American Bar Association (referenced regarding Model Rule 3.7)
|
|
| United States District Court for the Eastern District of New York |
Referenced in case citation (E.D.N.Y.)
|
Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
|
Eastern District of New York (referenced in legal citation)
|
Relationships (2)
Jack Scarola represented Carolyn in her 2008 lawsuit
her representative, Mr. Danchuck
Key Quotes (4)
"The defendant seeks to call three attorneys for victims: Jack Scarola, Brad Edwards, and Robert Glassman."Source
DOJ-OGR-00008376.jpg
Quote #1
"For each, the proposed testimony is either duplicative of facts already in evidence, is irrelevant or is improper impeachment."Source
DOJ-OGR-00008376.jpg
Quote #2
"Jack Scarola represented Carolyn in her 2008 lawsuit and before the Epstein Victims Compensation Program."Source
DOJ-OGR-00008376.jpg
Quote #3
"Carolyn did not contact the Government between 2007 and March 2019"Source
DOJ-OGR-00008376.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,806 characters)
Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 3 of 9
(AKT), 2017 WL 3037408, at *9 (E.D.N.Y. July 17, 2017) (“[T]here is a presumption disfavoring attorney depositions which is based on the recognition that even a deposition of counsel limited to relevant and non-privileged information risks disrupting the attorney-client relationship and impeding the litigation.” (alterations and internal quotation marks omitted)); ABA Model Rule 3.7 cmt. (noting potential conflict of interest issues that arise if, for instance, “there is likely to be substantial conflict between the testimony of the client and that of the lawyer”).
II. Discussion
The defendant seeks to call three attorneys for victims: Jack Scarola, Brad Edwards, and Robert Glassman. For each, the proposed testimony is either duplicative of facts already in evidence, is irrelevant or is improper impeachment. And in any event, whatever marginal probative value that testimony might offer is outweighed by the prejudice and jury confusion associated with calling an attorney to testify against his client.
A. Jack Scarola
The defendant proposes to call Jack Scarola, counsel for Carolyn, to testify about the course of his communications with the Government. While that testimony would not be privileged, it is irrelevant and improper impeachment.
Much of the testimony the defendant seeks from Scarola is evidence confirmed by Carolyn on cross-examination. Specifically, Carolyn agreed to the following facts:
• Jack Scarola represented Carolyn in her 2008 lawsuit and before the Epstein Victims Compensation Program. (Tr. 1617-18).
• Carolyn did not contact the Government between 2007 and March 2019, and then again was out of touch until her representative, Mr. Danchuck, responded in July 2020. (Tr.
3
DOJ-OGR-00008376
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document