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713 KB
Extraction Summary
4
People
3
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (government motion/response)
File Size:
713 KB
Summary
This page from a legal filing (United States v. Ghislaine Maxwell) argues against admitting a statement made by attorney Glassman to the Government on August 17, 2021, regarding his client 'Jane'. The Government contends the statement has minimal impeachment value because Jane's civil cases were already dismissed and she had been paid by the Epstein Victims' Compensation Fund prior to the statement. Additionally, the Government argues that admitting the statement risks violating attorney-client privilege regarding Glassman's advice to Jane.
People (4)
| Name | Role | Context |
|---|---|---|
| Jane | Victim/Witness |
Testified in the trial; received compensation from EVCP; subject of potential impeachment regarding her knowledge of ...
|
| Glassman | Attorney/Advisor |
Legal counsel to Jane; made a statement to the Government on August 17, 2021; asserted attorney-client privilege.
|
| Ghislaine Maxwell | Defendant |
Referenced as 'Ms. Maxwell'; defendant in the trial (Case 1:20-cr-00330-PAE).
|
| Jeffrey Epstein | Deceased Financier |
Referenced in 'Epstein Victims’ Compensation Fund' and 'Epstein estate'.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Epstein Victims’ Compensation Fund |
Fund that paid Jane; also referred to as EVCP.
|
|
| The Government |
Prosecution/DOJ; received statement from Glassman.
|
|
| Epstein Estate |
Entity involved in civil litigation against Jane.
|
Relationships (2)
Civil litigation against... Ms. Maxwell.
Key Quotes (4)
"cooperation with the government, including testifying, would benefit you in your civil litigation against the Epstein estate and Ms. Maxwell."Source
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Quote #1
"Jane had been paid by the Epstein Victims Compensation Fund, and her civil case had been dismissed."Source
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Quote #2
"Glassman referenced 'help[ing] her case,' which is not specifically a reference to civil litigation or her claim with the EVCP"Source
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Quote #3
"The Government is of course not aware of Glassman’s privileged advice to Jane."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,091 characters)
Case 1:20-cr-00330-PAE Document 528 Filed 12/06/21 Page 7 of 8
Government would have aided Jane’s claim before the Epstein Victims’ Compensation Fund and
that Jane was aware of that fact, as the defense has already argued. And insofar as the point is to
impeach Jane, this statement is of minimal impeachment value. Jane said no when asked whether
she knew that “cooperation with the government, including testifying, would benefit you in your
civil litigation against the Epstein estate and Ms. Maxwell.” 12/01/21 Tr. at 581; see id. (asking
the same question about her knowledge “at any point” regarding Jane’s civil litigation). As of
August 17, 2021, the date of the statement from Glassman to the Government, Jane had been paid
by the Epstein Victims Compensation Fund, and her civil case had been dismissed. And Glassman
appears to have advised Jane that the civil cases were fully resolved. See 12/01/21 Tr. at 619
(testimony by Jane that she does not have a financial stake in the outcome of this trial).4 At most,
then, the statement means that Glassman, at some point in the past, advised Jane that testifying
would aid another “case.” And at most, that would impeach Jane by suggesting that, while she
accurately testified that she did not “know” that her “cooperation with the government, including
testifying,” would benefit her in her civil case or EVCP claim, she had been told that at one point
in the past.
that Jane was aware of that fact, as the defense has already argued. And insofar as the point is to
impeach Jane, this statement is of minimal impeachment value. Jane said no when asked whether
she knew that “cooperation with the government, including testifying, would benefit you in your
civil litigation against the Epstein estate and Ms. Maxwell.” 12/01/21 Tr. at 581; see id. (asking
the same question about her knowledge “at any point” regarding Jane’s civil litigation). As of
August 17, 2021, the date of the statement from Glassman to the Government, Jane had been paid
by the Epstein Victims Compensation Fund, and her civil case had been dismissed. And Glassman
appears to have advised Jane that the civil cases were fully resolved. See 12/01/21 Tr. at 619
(testimony by Jane that she does not have a financial stake in the outcome of this trial).4 At most,
then, the statement means that Glassman, at some point in the past, advised Jane that testifying
would aid another “case.” And at most, that would impeach Jane by suggesting that, while she
accurately testified that she did not “know” that her “cooperation with the government, including
testifying,” would benefit her in her civil case or EVCP claim, she had been told that at one point
in the past.
By contrast, there is significant risk that admission of the statement would require
Glassman to divulge further privileged communications with Jane. Glassman’s comment to the
Government is not easily intelligible. Glassman referenced “help[ing] her case,” which is not
specifically a reference to civil litigation or her claim with the EVCP, and says that “it,” whatever
it is, would help that case. (Def. Letter Ex. A). To explain what Glassman is referencing, and
when he gave that advice, he would likely have to provide more content to his advice to Jane and
Glassman to divulge further privileged communications with Jane. Glassman’s comment to the
Government is not easily intelligible. Glassman referenced “help[ing] her case,” which is not
specifically a reference to civil litigation or her claim with the EVCP, and says that “it,” whatever
it is, would help that case. (Def. Letter Ex. A). To explain what Glassman is referencing, and
when he gave that advice, he would likely have to provide more content to his advice to Jane and
4 The Government is of course not aware of Glassman’s privileged advice to Jane.
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DOJ-OGR-00008243
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