DOJ-OGR-00019433.jpg
686 KB
Extraction Summary
7
People
2
Organizations
0
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal brief / court filing (page 29 of a larger document, document 60 in case 20-3061)
File Size:
686 KB
Summary
This document is page 29 (labeled Page 34 of 58 in the header) of a legal brief filed on September 24, 2020, on behalf of Ghislaine Maxwell. It argues that the government is acting inconsistently by intervening to stay proceedings in the civil case 'Doe v. Indyke' to protect the criminal prosecution's integrity, while failing to do the same in 'Giuffre v. Maxwell' regarding unsealing deposition materials. The text highlights that Jane Doe alleges abuse by both Epstein and Maxwell when she was a minor.
People (7)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Appellant |
Subject of the criminal prosecution and civil suits; seeking a stay of unsealing process.
|
| Jeffrey Epstein | Deceased/Alleged Perpetrator |
Mentioned in relation to allegations by Jane Doe in Doe v. Indyke.
|
| Jane Doe | Plaintiff |
Plaintiff in Doe v. Indyke alleging abuse by Epstein and Maxwell.
|
| Indyke | Defendant (Civil) |
Named defendant in Doe v. Indyke.
|
| Judge Nathan | Judge |
Presiding judge (likely criminal case) referenced in footnote 7 regarding the modification of a protective order.
|
| Judge Preska | Judge |
Presiding judge (likely civil case, Giuffre v. Maxwell) referenced in footnote 7.
|
| Virginia Giuffre | Plaintiff (implied) |
Implied via case name 'Giuffre v. Maxwell'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
US Department of Justice/Prosecution; intervened in Doe v. Indyke but not Giuffre v. Maxwell.
|
|
| DOJ |
Department of Justice (referenced in Bates stamp DOJ-OGR).
|
Relationships (3)
alleges that Epstein and Ms. Maxwell abused and exploited her as a minor
Jane Doe alleges that Epstein and Ms. Maxwell abused and exploited her as a minor
Judge Nathan should have modified... so Judge Preska could have evaluated
Key Quotes (4)
"Jane Doe alleges that Epstein and Ms. Maxwell abused and exploited her as a minor."Source
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Quote #1
"According to the government, a stay of that case was necessary to 'preserv[e] the integrity of the criminal prosecution against [Ms.] Maxwell.'"Source
DOJ-OGR-00019433.jpg
Quote #2
"This makes no principled sense if the government’s opposition to modifying the criminal protective order is to be"Source
DOJ-OGR-00019433.jpg
Quote #3
"Judge Nathan should have modified the criminal protective order so Judge Preska could have evaluated whether keeping the deposition material under seal would similarly 'preserve the integrity of the criminal prosecution against Ms. Maxwell.'"Source
DOJ-OGR-00019433.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,620 characters)
Case 20-3061, Document 60, 09/24/2020, 2938278, Page34 of 58
compromises Ms. Maxwell’s ability to seek a stay of the unsealing process and
thereby safeguard her right to a fair trial in the criminal case.
thereby safeguard her right to a fair trial in the criminal case.
The government can hardly dispute the merit of Ms. Maxwell’s argument
for a stay. After all, the government itself moved to intervene and to stay all
proceedings in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and
Ms. Maxwell abused and exploited her as a minor. ATTACHMENT B, p 4 (Doe v.
Indyke et al., No. 20-cv-00484, ECF Dkt. 81, 9/14/2020 Order Granting Motion to
Stay).6 According to the government, a stay of that case was necessary to
“preserv[e] the integrity of the criminal prosecution against [Ms.] Maxwell.” Id.
The court there agreed, and it granted Ms. Maxwell’s motion to stay. Id. at 12.7
for a stay. After all, the government itself moved to intervene and to stay all
proceedings in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and
Ms. Maxwell abused and exploited her as a minor. ATTACHMENT B, p 4 (Doe v.
Indyke et al., No. 20-cv-00484, ECF Dkt. 81, 9/14/2020 Order Granting Motion to
Stay).6 According to the government, a stay of that case was necessary to
“preserv[e] the integrity of the criminal prosecution against [Ms.] Maxwell.” Id.
The court there agreed, and it granted Ms. Maxwell’s motion to stay. Id. at 12.7
In contrast to Doe v. Indyke, the government has not moved to intervene in
Giuffre v. Maxwell, to stay the unsealing process, or to keep the deposition material
and Ms. Maxwell’s depositions under seal. This makes no principled sense if the
government’s opposition to modifying the criminal protective order is to be
Giuffre v. Maxwell, to stay the unsealing process, or to keep the deposition material
and Ms. Maxwell’s depositions under seal. This makes no principled sense if the
government’s opposition to modifying the criminal protective order is to be
__________________
6 This Court can take judicial notice of this order. See Fed. R. Evid.
201(c)(2).
7 If a stay in Doe v. Indyke preserves the integrity of the criminal prosecution
against Ms. Maxwell, Judge Nathan should have modified the criminal protective
order so Judge Preska could have evaluated whether keeping the deposition
material under seal would similarly “preserve the integrity of the criminal
prosecution against Ms. Maxwell.”
6 This Court can take judicial notice of this order. See Fed. R. Evid.
201(c)(2).
7 If a stay in Doe v. Indyke preserves the integrity of the criminal prosecution
against Ms. Maxwell, Judge Nathan should have modified the criminal protective
order so Judge Preska could have evaluated whether keeping the deposition
material under seal would similarly “preserve the integrity of the criminal
prosecution against Ms. Maxwell.”
29
DOJ-OGR-00019433
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