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This document is a Table of Contents for a legal filing (Case 20-3061, Document 61) dated September 24, 2020. It lists various legal documents filed between July and September 2020, including a Superseding Indictment, motions regarding a Protective Order (PO), and a Notice of Appeal. The index highlights the back-and-forth between the Defendants ('Defts') and the Government ('Govs'), including filings related to redactions and sealed documents.
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This legal document, filed on September 14, 2020, outlines the arguments surrounding a motion for a stay in a civil case involving a defendant named Maxwell. Maxwell requested the stay pending her criminal case, a motion supported by the Co-Executors who argued against a partial stay. The Plaintiff vigorously opposed the motion, accusing Maxwell of attempting to gain an unfair discovery advantage.
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This legal document, part of a court filing from March 2, 2020, outlines a procedural history involving civil protective orders in a criminal case. In 2019, the Government successfully modified a protective order in one court (Court-1) to obtain materials from a 'Recipient' for a grand jury, while another court (Court-2) denied a similar request. The current court is now permitting the Defendant, who learned of this through discovery, to provide this sealed information to Court-1 and Court-2 so those courts can determine whether to unseal related materials.
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This legal document is a court order denying a defendant's request to modify a previously established protective order. The defendant sought permission to use discovery materials, provided by the Government for a criminal case, in a separate civil proceeding. The court references the original protective order from July 30, 2020, which both parties had agreed to and which explicitly forbade such use, and ultimately denies the defendant's request.
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This document is the conclusion of a legal filing dated September 24, 2020, in Case 20-3061. The author argues that the Court should overturn a district court's decision, which would allow Ms. Maxwell to share information from her criminal case (under Judge Nathan) with Judge Preska in her civil case. The filing contends that the government's argument to prevent this sharing lacks a principled justification.
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This document is page 32 of a legal filing (dated Sept 24, 2020) arguing against the unsealing of deposition material. The text contends that unsealing the material would prevent Judge Preska from reconsidering her decision based on new information about how the government obtained the material, and would prejudice Ms. Maxwell's ability to argue before Judge Nathan that perjury counts should be dismissed due to the government's circumvention of the 'Martindell' precedent.
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This document is a legal filing, likely part of an appeal brief, dated September 24, 2020. The filing argues that the appellate court should overturn Judge Nathan's decision and modify a criminal protective order. The purpose of the modification is to allow Ms. Maxwell to share sealed information with Judge Preska regarding how the government obtained her deposition transcripts, which Judge Preska is considering unsealing.
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This page from a legal document argues that an appeal by Ms. Maxwell should be heard before her criminal trial concludes, otherwise it will become moot. The argument centers on her need to share information with Judge Preska for an ongoing unsealing process, a situation the author distinguishes from legal precedents like Caparros and Pappas.
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This legal document, part of Case 20-3061 dated September 24, 2020, presents an argument on behalf of Ms. Maxwell, countering the government's position. The author argues that the government misinterprets and improperly relies on two precedent cases, United States v. Caparros (1986) and United States v. Pappas (1996), regarding the appealability of protective orders. The document specifically analyzes the Caparros case to demonstrate why it is distinguishable from Ms. Maxwell's current situation.
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This legal document, dated September 24, 2020, describes a procedural issue in a case involving Ms. Maxwell. A criminal protective order issued by Judge Nathan prevented Ms. Maxwell from sharing critical information with Judge Preska regarding an unsealing process. Following Judge Preska's suggestion, Ms. Maxwell filed a motion with Judge Nathan to modify the order, seeking permission to share what she had learned under seal.
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This document is page 21 of a legal filing (Case 20-3061) dated September 16, 2020. The Government argues that the Court should deny Ghislaine Maxwell's motion to consolidate two separate appeals (one civil regarding unsealing, one criminal regarding a protective order). The text asserts that Maxwell's strategy is procedurally improper and attempts to litigate the Government's evidence-gathering methods in the wrong forum.
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This legal document, dated August 21, 2020, is a submission from the Acting United States Attorney and Assistant United States Attorneys to Honorable Alison J. Nathan. It argues against the defendant's application to use criminal discovery materials in civil cases, asserting that the application lacks legal justification, attempts to circumvent a protective order, and is irrelevant to the civil litigation. The document suggests the defendant's intent is to falsely accuse the Government and another party.
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This legal document, part of a court filing, outlines a procedural history concerning sealed information from civil matters. The Government successfully modified a protective order in one court (Court-1) but not another (Court-2) to obtain materials for a grand jury investigation, which were then turned over by a 'Recipient'. The current court is now permitting the Defendant, who learned of this through discovery, to provide the sealed information back to Court-1 and Court-2 for their own determination of relevance.
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This document is the third page of a legal letter from attorney David Boies to Judge Debra C. Freeman, dated May 18, 2020, regarding a civil case against Ghislaine Maxwell. Boies argues that the court should deny Maxwell's motion to stay discovery and her request for a pre-motion conference, citing Judge Schofield's previous comments that Maxwell's motion to dismiss lacks merit. The letter also asserts that the existence of the Epstein Estate's Victim Compensation Fund (in the Virgin Islands probate court) is not a valid reason to stay the current action without the Plaintiff's consent.
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This document is page 10 of a legal court order, filed on July 30, 2020, that outlines strict procedures for handling confidential discovery materials in a criminal case. It details how the Defendant and their counsel can inspect evidence under supervision and explicitly prohibits the entire defense team from publicly filing any confidential information without written authorization from the Government or an Order of the Court.
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This document is a page from a court order filed on July 30, 2020, related to case 1:20-cr-00330-AJN. It outlines the specific categories of individuals associated with the legal defense (staff, experts, witnesses) who are permitted to receive sensitive discovery materials. The order strictly requires that any such 'Designated Person' must first sign a copy of the order, formally agreeing to be bound by its terms, before being granted access to the materials.
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This document is a Certificate of Service dated September 10, 2020, signed by Nicole Simmons. It certifies that Ghislaine Maxwell's Motion to Consolidate Appeal was filed with the Court via CM/ECF and a copy was emailed to all counsel of record on that date. The document confirms the proper legal service of the motion.
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This legal document, part of Case 20-3061 dated September 10, 2020, argues for the consolidation of legal cases. The author contends that having separate panels for criminal and civil cases creates an unfair situation, and cites inconsistent rulings from judges in the Southern District of New York as having prejudiced Ms. Maxwell.
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This legal document is a motion filed by Defendant-Appellant Ghislaine Maxwell on September 10, 2020, requesting the consolidation of two appeals. The first is from her criminal case (United States v. Maxwell) and the second is from a civil case (Giuffre v. Maxwell). Maxwell argues the cases are intertwined because new information from the criminal case is relevant to the court's decision to unseal deposition material in the civil case.
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This document is a Certificate of Service from Case 20-3061, dated September 10, 2020. In it, Nicole Simmons certifies that she filed an 'Unopposed Motion to File Motion to Consolidate under Seal' with the Court via the CM/ECF system and also emailed a copy of the motion to all counsel of record on the same day.
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This legal document, part of an appeal (Case 20-3061), explains the procedural constraints on Ms. Maxwell due to conflicting court orders. A criminal protective order from Judge Nathan prevents her from sharing critical information with Judge Preska in a related civil case. Consequently, Ms. Maxwell must file a redacted version of her Motion to Consolidate publicly, while the full, unredacted version can only be filed under seal in the criminal appeal.
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This document is a page from a court docket in the case of United States v. Ghislaine Maxwell, listing entries from late July 2020. It includes an affidavit filing, correspondence regarding a protective order, the order itself, and a lengthy Memorandum Opinion & Order by Judge Alison J. Nathan resolving disputes over the protective order's terms regarding public references to victims/witnesses and the use of discovery materials. The court ruled in favor of the Government's proposed language, prioritizing the privacy of alleged victims and witnesses.
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This document is a page from the court docket for Case 20-3061 involving Ghislaine Maxwell, covering entries from July 8 to July 9, 2020. It records procedural orders regarding remote proceedings, Speedy Trial Act exclusions, and victim notification rights, as well as the filing of attorney appearances, a pro hac vice motion, and a superseding indictment. The document also details the scheduling of an arraignment and bail hearing via teleconference.
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This document is a court transcript of a legal summation. The speaker first attempts to discredit an unnamed witness by claiming she was paid $5 million by the government and that her stories of flying are uncorroborated. The speaker then discusses the testimony of Annie Farmer, a psychologist, stating the court has instructed that the alleged incident with Mr. Epstein and Ms. Maxwell in New Mexico was not illegal as charged, and that it was Annie's sister, Maria, who worked for Epstein and introduced them.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2009-09-17 | Received | Burman, Critton, ... | Court | $138.80 | Invoice for cancelled deposition services (Appe... | View |
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