DOJ-OGR-00015094.jpg
697 KB
Extraction Summary
5
People
4
Organizations
2
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing / defense motion response
File Size:
697 KB
Summary
This document is page 8 of a legal filing submitted on August 5, 2025, by the defense firm Markus/Moss in the case of United States v. Ghislaine Maxwell. The text argues against the government's motion to unseal grand jury transcripts, distinguishing Maxwell's case from *In re Biaggi* and rejecting a Florida public records case as irrelevant to federal Rule 6(e) protections. The defense concludes that there is no precedent for unsealing such transcripts in an ongoing matter and requests the motion be denied.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal defense; opposing the unsealing of grand jury materials.
|
| Biaggi | Historical Legal Figure |
Referenced in case law 'In re Biaggi' regarding waiver of grand jury secrecy.
|
| Dave Aronberg | Party in cited case |
Named in 'CA Florida Holdings v. Dave Aronberg'.
|
| Joseph Abruzzo | Party in cited case |
Named in 'CA Florida Holdings, LLC v. Dave Aronberg and Joseph Abruzzo'.
|
| Markus/Moss | Defense Counsel |
Law firm listed in the footer representing Maxwell.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Southern District of New York |
Jurisdiction mentioned in the Biaggi precedent.
|
|
| Second Circuit |
Affirmed the district court's order in the Biaggi case.
|
|
| CA Florida Holdings, LLC |
Involved in a Florida public records lawsuit cited by the government.
|
|
| Department of Justice (DOJ) |
Implied by 'DOJ-OGR' Bates stamp and 'government' references.
|
Timeline (2 events)
2024-07-01
Order in CA Florida Holdings case cited in the text.
Florida (15th Circuit)
2025-08-05
Filing of Document 803 in Case 1:20-cr-00330-PAE.
US District Court
Defense Counsel
Court
Locations (2)
| Location | Context |
|---|---|
|
Legal jurisdiction.
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|
|
Jurisdiction of the cited case 'CA Florida Holdings'.
|
Relationships (1)
Text references 'the government's motion' which Maxwell opposes.
Key Quotes (3)
"Maxwell, unlike Biaggi, has preserved her right to grand jury secrecy and vigorously opposes disclosure of the grand jury materials."Source
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Quote #1
"There is no precedent for unsealing grand jury transcripts in an ongoing matter like Maxwell’s case."Source
DOJ-OGR-00015094.jpg
Quote #2
"Accordingly, the government’s motion should be denied."Source
DOJ-OGR-00015094.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,781 characters)
Case 1:20-cr-00330-PAE Document 803 Filed 08/05/25 Page 8 of 9
government in In re Biaggi moved to unseal Biaggi’s grand jury testimony only after
Biaggi petitioned a three-judge panel in the Southern District of New York to examine
his grand jury testimony and publicly report whether he had invoked any
constitutional privileges relating to his personal finances or assets. Id. at 491. The
Second Circuit affirmed the district court’s order directing the public disclosure of
Biaggi’s testimony based solely on his waiver, finding that “no matter how much, or
how legitimately, the public may want to know whether a candidate for high public
office has invoked the privilege against self-incrimination before a grand jury, or has
lied about having done so, that interest must generally yield to the larger one of
preserving the salutary rule of law embodied in Rule 6(e) of Federal Rules of Criminal
Procedure. But that is not this case.” Id. at 493 (emphasis added). Maxwell, unlike
Biaggi, has preserved her right to grand jury secrecy and vigorously opposes
disclosure of the grand jury materials.
Biaggi petitioned a three-judge panel in the Southern District of New York to examine
his grand jury testimony and publicly report whether he had invoked any
constitutional privileges relating to his personal finances or assets. Id. at 491. The
Second Circuit affirmed the district court’s order directing the public disclosure of
Biaggi’s testimony based solely on his waiver, finding that “no matter how much, or
how legitimately, the public may want to know whether a candidate for high public
office has invoked the privilege against self-incrimination before a grand jury, or has
lied about having done so, that interest must generally yield to the larger one of
preserving the salutary rule of law embodied in Rule 6(e) of Federal Rules of Criminal
Procedure. But that is not this case.” Id. at 493 (emphasis added). Maxwell, unlike
Biaggi, has preserved her right to grand jury secrecy and vigorously opposes
disclosure of the grand jury materials.
Lastly, the Florida case the government cites, CA Florida Holdings v. Dave
Aronberg, has no precedential value in this jurisdiction and involved a civil suit under
Florida public records law, not federal grand jury materials protected under Rule 6(e).
See Order Granting Plaintiff’s Motion for Reconsideration of the Trial Court’s
February 29, 2024 Order, CA Florida Holdings, LLC v. Dave Aronberg and Joseph
Abruzzo, 50-2019 CA-014681 (15th Cir. July 1, 2024). It is wholly inapposite.
Aronberg, has no precedential value in this jurisdiction and involved a civil suit under
Florida public records law, not federal grand jury materials protected under Rule 6(e).
See Order Granting Plaintiff’s Motion for Reconsideration of the Trial Court’s
February 29, 2024 Order, CA Florida Holdings, LLC v. Dave Aronberg and Joseph
Abruzzo, 50-2019 CA-014681 (15th Cir. July 1, 2024). It is wholly inapposite.
There is no precedent for unsealing grand jury transcripts in an ongoing
matter like Maxwell’s case. Accordingly, the government’s motion should be denied.
matter like Maxwell’s case. Accordingly, the government’s motion should be denied.
MARKUS/MOSS
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DOJ-OGR-00015094
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