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Extraction Summary

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

Document Information

Type: Legal document
File Size: 528 KB
Summary

This legal document is a letter dated October 18, 2021, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan on behalf of his client, Ms. Maxwell. Pagliuca argues that due to recent government disclosures and a cumbersome two-step file encryption process implemented by the government, there has been insufficient time to meet the deadline for filing motions *in limine*. Citing a previous court order, he reserves the right for the defense to file additional or supplemental motions after the deadline has passed.

People (3)

Name Role Context
Alison J. Nathan The Honorable
The recipient of the letter, presumably the judge presiding over the case.
Maxwell Defendant/Client
Referred to as 'Ms. Maxwell', she is the subject of the legal filing, whose counsel is arguing for more time.
Jeffrey S. Pagliuca Counsel
The author of the letter, submitting it on behalf of Ms. Maxwell.

Organizations (2)

Name Type Context
the Court government agency
Mentioned as a party with whom concerns were previously raised and as the entity that issued a previous order.
the government government agency
The opposing party in the legal case, responsible for disclosures and encrypting files.

Timeline (3 events)

2021-06-02
The Court issued an order (Dkt. 297) allowing parties to bring issues to its attention after the deadline if they could not have been raised before.
2021-10-11
The government's disclosure of Jencks Act, Giglio material and government exhibits.
2021-10-18
The deadline to prepare and submit additional filings (motions in limine).

Relationships (2)

Jeffrey S. Pagliuca professional Maxwell
Pagliuca is identified as Ms. Maxwell's counsel and is submitting the legal document on her behalf.
Maxwell adversarial the government
The document describes a legal case where the government is providing disclosures (as the prosecution) to Maxwell's counsel (the defense).

Key Quotes (2)

"In addition, and as requested by the parties, the parties may bring issues to the Court's attention that arise after the deadline for motions in limine if the issues could not have been raised within the deadline set for in limine motions."
Source
— 6/2/2021 Order (Dkt. 297) (Quoted from a previous court order to support the request to file motions after the deadline.)
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Quote #1
"This two-step process has slowed the review process."
Source
— Jeffrey S. Pagliuca (From a footnote explaining how the government's encryption method for discovery files has created delays for the defense.)
DOJ-OGR-00005263.jpg
Quote #2

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