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668 KB

Extraction Summary

3
People
2
Organizations
0
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Court filing / legal brief (appellate)
File Size: 668 KB
Summary

This document is page 5 of a court filing dated September 16, 2020, detailing the Government's opposition to Ghislaine Maxwell's motion to modify a protective order. It outlines the history of grand jury subpoenas issued to an unnamed 'Recipient' in 2019 as part of an investigation into Jeffrey Epstein and his co-conspirators. The text explains that the Government sought to modify civil protective orders ex parte in February 2019 to allow the Recipient to comply with these subpoenas without notifying Maxwell to preserve the investigation's integrity.

People (3)

Name Role Context
Ghislaine Maxwell Defendant/Litigant
Seeking authorization to use materials in separate civil litigation; filed a motion to modify a Protective Order.
Jeffrey Epstein Subject of Investigation
Subject of a grand jury investigation regarding himself and possible co-conspirators.
The Recipient Subpoena Recipient
An unnamed entity that received grand jury subpoenas and advised the Government regarding conflict with existing prot...

Organizations (2)

Name Type Context
The Government
Filed opposition to Maxwell's motion; conducted grand jury investigation.
District Court
Venue where docket entries 52 and 46 were filed.

Timeline (2 events)

2019-02
Government applied ex parte and under seal to relevant courts to modify protective orders.
Relevant Courts
2020-08-21
Government filed an opposition to Maxwell’s motion to modify the Protective Order (Dist. Ct. Docket Entry 46).
District Court

Relationships (2)

Jeffrey Epstein Co-conspirator (alleged) Ghislaine Maxwell
Investigation into 'Jeffrey Epstein and his possible co-conspirators' in the context of a case involving Maxwell.
The Government Legal/Investigative The Recipient
Government issued subpoenas to Recipient; Recipient advised Government regarding compliance issues.

Key Quotes (3)

"Those Subpoenas were issued to a certain recipient (the “Recipient”) in connection with a grand jury investigation into Jeffrey Epstein and his possible co-conspirators."
Source
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Quote #1
"In order to maintain the integrity of the grand jury investigation... the Government did not notify Maxwell or her counsel of the Subpoenas."
Source
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Quote #2
"Accordingly, in or about February 2019, the Government applied ex parte and under seal to each relevant court"
Source
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Quote #3

Full Extracted Text

Complete text extracted from the document (1,589 characters)

Case 20-3061, Document 37, 09/16/2020, 2932231, Page5 of 24
Government, in filings Maxwell intended to submit in separate civil litigation.
(District Court Docket Entry 52). In particular, Maxwell’s motion sought
authorization to use materials relating to applications the Government previously
made in 2019 seeking the modification of certain protective orders in other judicial
proceedings.
5. On August 21, 2020, the Government filed an opposition to
Maxwell’s motion to modify the Protective Order. (Dist. Ct. Docket Entry 46). In
its opposition, the Government explained the factual background regarding the
confidential criminal discovery materials at issue. In particular, the Government
explained that those discovery materials related to the Government’s requests to
modify certain protective orders in civil cases to permit compliance with grand
jury subpoenas (the “Subpoenas”). Those Subpoenas were issued to a certain
recipient (the “Recipient”) in connection with a grand jury investigation into
Jeffrey Epstein and his possible co-conspirators. In order to maintain the integrity
of the grand jury investigation and in accordance with both Federal Rule of
Criminal Procedure 6(e) and its standard practice, the Government did not notify
Maxwell or her counsel of the Subpoenas. In response to receiving the Subpoenas,
the Recipient advised the Government that it believed that certain existing
protective orders precluded full compliance. Accordingly, in or about February
2019, the Government applied ex parte and under seal to each relevant court to
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