EFTA00027169.pdf

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Extraction Summary

4
People
4
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence / motion response
File Size: 307 KB
Summary

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)

2021-04-22
Filing of defense letter responding to government's position on suppression motions.
Southern District of New York
Unknown
Ex parte proceeding where government allegedly misled Chief Judge McMahon to obtain a subpoena.
Court
Government Chief Judge McMahon

Locations (2)

Location Context
Address of Haddon, Morgan and Foreman, P.C.
Address of the United States District Court, SDNY.

Relationships (2)

Ghislaine Maxwell Client-Attorney Jeffrey S. Pagliuca
Pagliuca writes on Maxwell's behalf as her counsel.
Alison J. Nathan Judge-Defendant Ghislaine Maxwell
Nathan is the judge presiding over Maxwell's criminal case.

Key Quotes (4)

"The government’s representation is not good enough, and its reservation of rights is misplaced."
Source
EFTA00027169.pdf
Quote #1
"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
EFTA00027169.pdf
Quote #2
"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
EFTA00027169.pdf
Quote #3
"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
EFTA00027169.pdf
Quote #4

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