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Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Court filing (motion for discovery/disclosure)
File Size:
695 KB
Summary
This document is page 15 of a court filing in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It outlines Maxwell's requests for documents related to her motions to dismiss the indictment (based on Epstein's Non-Prosecution Agreement) and to suppress evidence obtained via a subpoena to a redacted party. The document asserts Maxwell was unaware of this subpoena and seeks its production to determine grounds for challenge, while also initiating a motion for the immediate disclosure of exculpatory (Brady) and impeachment (Giglio) material.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Filing motions to dismiss indictment and suppress evidence; requesting discovery and subpoenas.
|
| Jeffrey Epstein | Deceased Co-conspirator |
Mentioned in relation to the Non-Prosecution Agreement (NPA) breach argument.
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| AJN | Judge (Alison J. Nathan) |
Presiding judge indicated in the case number stamp (Case 1:20-cr-00330-AJN).
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
The prosecution (Department of Justice), opposing Maxwell's motions.
|
|
| The Court |
The judicial body being petitioned.
|
Timeline (2 events)
Relationships (2)
Maxwell is using Epstein's Non-Prosecution Agreement as a basis for her motion to dismiss.
Maxwell is the defendant requesting documents that the government previously denied.
Key Quotes (4)
"Ms. Maxwell has filed a motion to dismiss the indictment for breach of the Non-Prosecution Agreement entered into by Jeffrey Epstein"Source
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Quote #1
"Ms. Maxwell was not aware that the subpoena had been issued and never had the opportunity to contest it."Source
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Quote #2
"Ms. Maxwell seeks a copy of the subpoena to determine whether she has a basis to challenge it."Source
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Quote #3
"Ms. Maxwell moves for an order... compelling the government to [produce Brady and Giglio material]"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,012 characters)
Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 15 of 23
C. Documents Related to Ms. Maxwell’s Motions
Along with this motion, Ms. Maxwell has filed a motion to dismiss the indictment for
breach of the Non-Prosecution Agreement entered into by Jeffrey Epstein and two motions to
suppress the evidence obtained from the government’s subpoena of [REDACTED]. These
motions request, as alternative relief, that the Court grant discovery and an evidentiary hearing
on the issues bearing on the motions. Ms. Maxwell asked the government for documents
relevant to these motions, but was denied. To the extent that the Court grants discovery related
to these two motions, Ms. Maxwell requests, among other things, the documents requested in
Exhibit E, which were previously requested from the government. (See Ex. E).
breach of the Non-Prosecution Agreement entered into by Jeffrey Epstein and two motions to
suppress the evidence obtained from the government’s subpoena of [REDACTED]. These
motions request, as alternative relief, that the Court grant discovery and an evidentiary hearing
on the issues bearing on the motions. Ms. Maxwell asked the government for documents
relevant to these motions, but was denied. To the extent that the Court grants discovery related
to these two motions, Ms. Maxwell requests, among other things, the documents requested in
Exhibit E, which were previously requested from the government. (See Ex. E).
Ms. Maxwell also requests the Court to order the government to produce a copy of the
subpoena that it issued to [REDACTED]. As set forth in Ms. Maxwell’s motion to suppress,
[REDACTED], Ms.
Maxwell was not aware that the subpoena had been issued and never had the opportunity to
contest it. Ms. Maxwell seeks a copy of the subpoena to determine whether she has a basis to
challenge it.
subpoena that it issued to [REDACTED]. As set forth in Ms. Maxwell’s motion to suppress,
[REDACTED], Ms.
Maxwell was not aware that the subpoena had been issued and never had the opportunity to
contest it. Ms. Maxwell seeks a copy of the subpoena to determine whether she has a basis to
challenge it.
Likewise, for the reasons set forth in her motion to suppress, Ms. Maxwell requests that
the government produce copies of the other grand jury subpoenas issued in connection with this
case for the production of Ms. Maxwell’s private and confidential records.⁶
the government produce copies of the other grand jury subpoenas issued in connection with this
case for the production of Ms. Maxwell’s private and confidential records.⁶
III. Motion for Immediate Disclosure of Brady and Giglio Material
Ms. Maxwell moves for an order, pursuant to Brady v. Maryland, 373 U.S. 83 (1963)
and its progeny, Kyles v. Whitley, 514 U.S. 419 (1995), United States v. Bagley, 473 U.S. 667
(1985), and Giglio v. United States, 405 U.S. 150 (1972) compelling the government to
and its progeny, Kyles v. Whitley, 514 U.S. 419 (1995), United States v. Bagley, 473 U.S. 667
(1985), and Giglio v. United States, 405 U.S. 150 (1972) compelling the government to
⁶ See Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence
Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six.
Obtained from the Government’s Subpoena to [REDACTED] and to Dismiss Counts Five and Six.
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DOJ-OGR-00002708
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