September 24, 2020
Filing of Document 60 in Case 20-3061.
| Name | Type | Mentions | |
|---|---|---|---|
| Ms. Maxwell's legal counsel | person | 0 | View Entity |
| Legal Counsel | person | 2 | View Entity |
| The government | organization | 3113 | View Entity |
| Ms. Maxwell | person | 1982 | View Entity |
| GHISLAINE MAXWELL | person | 9575 | View Entity |
DOJ-OGR-00019428.jpg
A page from a legal filing (Case 20-3061) dated September 24, 2020. The text argues that the government failed to follow proper procedures to access court-protected documents from a civil case. It highlights Ms. Maxwell's unique position as the only individual involved in all six related judicial proceedings.
DOJ-OGR-00019436.jpg
This is a page from a legal filing (Case 20-3061) dated September 24, 2020. The text argues that Judge Preska erred by ignoring Ghislaine Maxwell's 'reliance argument.' It states that Maxwell did not plead the Fifth Amendment during her depositions because she relied on a civil protective order and the *Martindell* precedent, which protects witness testimony from being used by the Government for criminal investigations or perjury charges.
DOJ-OGR-00019404.jpg
This document is page 5 of a 58-page legal filing (Document 60, Case 20-3061) dated September 24, 2020. It is a table of authorities, listing legal cases, federal rules of procedure, and statutes that are cited within the larger document. The page numbers provided indicate where each authority is referenced.
DOJ-OGR-00019427.jpg
This is a page from a legal brief filed on September 24, 2020, in Case 20-3061. It argues that Judge Nathan erred by not modifying a protective order, preventing Ghislaine Maxwell from sharing sealed material with Judge Preska, which the defense claims is necessary to protect Maxwell's rights under the *Martindell* precedent. The document highlights the complexity of the litigation, noting that six sets of judicial officers are handling interrelated questions regarding Maxwell.
DOJ-OGR-00019423.jpg
This document is page 24 (labeled 19 in the brief) of a legal filing dated September 24, 2020, related to Ghislaine Maxwell's appeal. It argues that Maxwell must be allowed to share specific information with Judge Preska to properly decide on unsealing deposition materials and a motion to stay, invoking *Martindell* protections and the Fifth Amendment. The text criticizes the government for attempting to keep relevant information secret from a 'co-equal' judge.
DOJ-OGR-00019430.jpg
This document is a page from a legal brief filed on September 24, 2020, in Case 20-3061 (Giuffre v. Maxwell). It argues that Ghislaine Maxwell is being treated unfairly because she is barred from sharing information sealed under a criminal protective order with judicial officers in her civil unsealing proceedings (presided over by Judge Preska). The brief asserts that the district court erred and abused its discretion by declining to modify the protective order under Federal Rule of Criminal Procedure 16(d)(1).
DOJ-OGR-00019431.jpg
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 page is from a legal brief (Case 20-3061, Document 60) filed on September 24, 2020. It argues that if Ms. Maxwell cannot appeal Judge Nathan's order via the 'collateral order doctrine,' the appellate court should instead issue a 'writ of mandamus' to modify the protective order. The document outlines legal precedents and the three specific conditions required to issue such a writ.
DOJ-OGR-00019433.jpg
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.
DOJ-OGR-00019401.jpg
This document is the table of contents for a legal filing (Document 60, Case 20-3061) dated September 24, 2020. The filing's primary argument is that Judge Nathan incorrectly refused to modify a protective order, which would have allowed Ms. Maxwell to share sealed material information with Judge Preska. The document outlines the structure of the legal brief, including the case history, jurisdictional statements, and the specific points of the argument.
DOJ-OGR-00019425.jpg
This document is page 21 (filed as page 26) of a legal brief in Case 20-3061, filed on September 24, 2020. It argues that a writ of mandamus is appropriate because Judge Nathan abused her discretion regarding a protective order and Judge Preska's unsealing order relies on inconsistent decisions within the Southern District of New York. The text discusses the unsealing of deposition materials and claims prejudice against Ms. Maxwell, though specific details are heavily redacted.
Events with shared participants
Notice of Appearance as Substitute Counsel filed on behalf of Appellant Ghislaine Maxwell
2021-03-30 • 02nd Circuit Court of Appeals
A shipment discussed in court, sent from Ghislaine Maxwell to Casey Wasserman. The event is stated to have occurred in 'October'.
Date unknown
A meeting where the government showed the witness (Visoski) records of three flights.
Date unknown
LETTER REPLY TO RESPONSE to Motion filed by Ghislaine Maxwell.
2020-07-29
Ms. Maxwell has been incarcerated for 225 days in de facto solitary confinement, monitored 24 hours a day by guards with a handheld camera.
2021-02-16 • MDC
Ms. Maxwell is being forced to prepare for trial with a computer that cannot do research or search documents, which is argued to be an inconceivable condition for preparation.
Date unknown • prison/jail
Filing or processing of the Reply Memorandum in Support of Third Motion for Bail
2021-04-01 • Federal Court (Implied)
The Government entered into a Non-Prosecution Agreement (NPA) with Jeffrey Epstein.
2007-01-01
Lawyers for accusers met with the Government to convince them to open an investigation of Ms. Maxwell.
2016-01-01
The Government gave on-the-record assurances to the Court regarding investigative files.
2020-07-14
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