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735 KB
Extraction Summary
6
People
2
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / appellate brief (page 3)
File Size:
735 KB
Summary
Page 3 of a legal filing (Case 20-3061) dated September 23, 2020, arguing against the unsealing of documents. Maxwell's defense contends that unsealing her deposition in a civil case (*Doe v. Indyke*) would prejudice her ability to litigate Fifth Amendment rights in her parallel criminal case before Judge Nathan. The document accuses the government of gamesmanship regarding the stay of proceedings.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Appellant |
Subject of criminal prosecution and civil litigation; seeking to keep deposition sealed.
|
| Jeffrey Epstein | Deceased/Alleged Abuser |
Alleged to have abused and exploited Jane Doe alongside Maxwell.
|
| Jane Doe | Plaintiff |
Plaintiff in civil case Doe v. Indyke; alleges abuse by Epstein and Maxwell as a minor.
|
| Indyke | Defendant (Civil) |
Named party in Doe v. Indyke.
|
| Judge Preska | Judge |
Issued an unsealing order in the civil case.
|
| Judge Nathan | Judge |
Presiding over the criminal case against Maxwell.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The government |
Prosecution; Department of Justice.
|
|
| The Court |
Appellate court reviewing the unsealing order.
|
Timeline (1 events)
2020-09-14
Relationships (2)
Text states Jane Doe alleges 'Epstein and Ms. Maxwell abused and exploited her as a minor.'
Maxwell intends to make arguments to Judge Nathan in the criminal case.
Key Quotes (3)
"Jane Doe alleges that Epstein and Ms. Maxwell abused and exploited her as a minor."Source
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Quote #1
"This Court should not let the government engage in such obvious gamesmanship."Source
DOJ-OGR-00019396.jpg
Quote #2
"Keeping the deposition material sealed will preserve the status quo and protect Ms. Maxwell’s right to litigate Martindell and the Fifth Amendment in the criminal proceeding."Source
DOJ-OGR-00019396.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,745 characters)
Case 20-3061, Document 54, 09/23/2020, 2937091, Page3 of 6
case and to stay the unsealing process, just as it moved to intervene and to stay
discovery in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and
Ms. Maxwell abused and exploited her as a minor. According to the government, a
stay of that case was necessary to "preserv[e] the integrity of the criminal
prosecution against [Ms.] Maxwell." Doe v. Indyke et al., No. 20-cv-00484, Doc.
81, p 4, 9/14/2020 Order Granting Motion to Stay. The court there agreed, and it
granted Ms. Maxwell’s motion to stay. Id. at 12. This Court should not let the
government engage in such obvious gamesmanship.
discovery in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and
Ms. Maxwell abused and exploited her as a minor. According to the government, a
stay of that case was necessary to "preserv[e] the integrity of the criminal
prosecution against [Ms.] Maxwell." Doe v. Indyke et al., No. 20-cv-00484, Doc.
81, p 4, 9/14/2020 Order Granting Motion to Stay. The court there agreed, and it
granted Ms. Maxwell’s motion to stay. Id. at 12. This Court should not let the
government engage in such obvious gamesmanship.
The government insists that, in these two appeals, Ms. Maxwell is "ask[ing]
this Court to rule on . . . the lawfulness of the Government’s applications to modify
certain protective orders in other judicial proceedings." Doc. 113, ¶ 27. That is not
so. The government’s contention mischaracterizes Ms. Maxwell’s argument.
this Court to rule on . . . the lawfulness of the Government’s applications to modify
certain protective orders in other judicial proceedings." Doc. 113, ¶ 27. That is not
so. The government’s contention mischaracterizes Ms. Maxwell’s argument.
As Ms. Maxwell said in her opening brief:
The civil case is not the appropriate forum to litigate the
government’s apparent violation of Martindell. Ms. Maxwell intends
to make that argument to Judge Nathan in the criminal case. But if
Judge Preska’s unsealing order is affirmed and Ms. Maxwell’s
deposition is released, her ability to make that argument before Judge
Nathan will be prejudiced. Keeping the deposition material sealed will
preserve the status quo and protect Ms. Maxwell’s right to litigate
Martindell and the Fifth Amendment in the criminal proceeding.
government’s apparent violation of Martindell. Ms. Maxwell intends
to make that argument to Judge Nathan in the criminal case. But if
Judge Preska’s unsealing order is affirmed and Ms. Maxwell’s
deposition is released, her ability to make that argument before Judge
Nathan will be prejudiced. Keeping the deposition material sealed will
preserve the status quo and protect Ms. Maxwell’s right to litigate
Martindell and the Fifth Amendment in the criminal proceeding.
Doc. 69, p 33. Only by mischaracterizing Ms. Maxwell’s argument can the
government contend that she is "ask[ing] this Court to rule on . . . the lawfulness of
government contend that she is "ask[ing] this Court to rule on . . . the lawfulness of
3
DOJ-OGR-00019396
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