Mega Edition: Ghislaine Maxwell Motion For Rule 45 Sanctions Against Virginia Roberts (Part 1-2) (8/19/25)

The Epstein Chronicles

In October 2020, Ghislaine Maxwell filed a combined memorandum opposing Virginia Roberts Giuffre’s request to extend the deposition deadline and, separately, moved for sanctions under Federal Rule 45. Maxwell argued that Giuffre served subpoenas in ways that directly violated Rule 45(a)(4), which requires timely pre-notice to all parties before serving a non‑party subpoena for documents. Specifically, Maxwell noted that Giuffre attempted to subpoena witnesses—such as Jeffrey Epstein, Sarah Kellen, and Nadia Marcincova—without providing proper advance notice to the defense, including issuing subpoenas before notifying Maxwell’s counsel
Maxwell framed this as part of a broader pattern of bad‑faith discovery tactics: she emphasized that Giuffre squandered the discovery period, failed to diligently schedule depositions, and attempted to secure depositions well past the court‑ordered cutoff without showing good cause. In support, she detailed her own efforts to coordinate schedules and comply with rules, contrasted with Giuffre’s “last‑minute scramble,” and urged the court to reject the extension of deadlines and impose sanctions under Rule 45 and Rule 37 for the procedural violations
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source:
gov.uscourts.nysd.447706.1137.19.pdf (free.law)
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