EFTA00027169.pdf
Extraction Summary
Document Information
Defense attorney Jeffrey Pagliuca writes to Judge Alison Nathan arguing against the government's request to defer ruling on Ghislaine Maxwell's motion to suppress evidence until after the trial on non-perjury counts. The defense contends that an evidentiary hearing is necessary immediately because the government's alleged misconduct (misleading a judge to obtain a subpoena) constitutes a due process violation that could suppress all 90,000 pages of evidence and any derivatives ('fruit of the poisonous tree'). Furthermore, the defense argues that Maxwell cannot knowingly decide whether to testify without knowing the admissibility of this evidence, as the government has only promised not to use it in its case-in-chief but reserved rights for impeachment.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case and the motion to suppress evidence.
|
| Alison J. Nathan | Judge |
United States District Court Judge, Southern District of New York; recipient of the letter.
|
| Jeffrey S. Pagliuca | Defense Attorney |
Author of the letter; represents Ghislaine Maxwell.
|
| Colleen McMahon | Chief Judge |
Mentioned as 'Chief Judge McMahon'; the defense alleges the government misled her in an ex parte proceeding.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
The court where the case is being heard.
|
|
| United States Government |
Prosecution in the case.
|
|
| Second Circuit Court of Appeals |
Referenced in legal citations (e.g., Martindell v. International Tel. & Tel. Corp.).
|
Timeline (2 events)
Locations (2)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
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|
|
Address of the United States District Court, SDNY.
|
Relationships (2)
Key Quotes (4)
"The government’s representation is not good enough, and its reservation of rights is misplaced."Source
"If this Court agrees with Ms. Maxwell’s arguments, not only will it suppress all 90,000-some pages of material the government improperly obtained through its ex parte subpoena, it will also suppress all evidence derived therefrom."Source
"Here, the government violated due process when it misrepresented and misled Chief Judge McMahon in an ex parte proceeding to circumvent the civil protective order..."Source
"Unless Ms. Maxwell knows what evidence the government can use against her... she cannot make a knowing and voluntary decision about whether to testify and or to assert her right to remain silent."Source
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