EFTA00029590.pdf

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Extraction Summary

5
People
3
Organizations
1
Locations
4
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence / letter to judge
File Size: 288 KB
Summary

Defense attorney Jeffrey Pagliuca writes to Judge Nathan objecting to the government's recent attempts to avoid disclosing the identities of unnamed co-conspirators and specific co-conspirator statements intended for trial. The defense characterizes the government's position as an improper 'motion to reconsider' prior court orders without showing extraordinary circumstances. The letter requests the Court confirm its orders requiring disclosure by October 11, 2021, to allow the defense to prepare motions in limine regarding the admissibility of statements from Jeffrey Epstein and an unnamed employee.

People (5)

Name Role Context
Jeffrey S. Pagliuca Defense Attorney
Author of the letter representing Ghislaine Maxwell.
Alison J. Nathan Judge
Recipient of the letter, District Court Judge.
Ghislaine Maxwell Defendant
Subject of the criminal case, seeking disclosure of co-conspirator identities and statements.
Jeffrey Epstein Co-conspirator (Deceased)
Named by the government as one of the two individuals whose statements they intend to offer at trial.
Unnamed Employee of Epstein Co-conspirator
Referenced in paragraph 25(d) of the S2 Indictment; government intends to offer their statements.

Organizations (3)

Name Type Context
Haddon, Morgan and Foreman, p.c.
Law firm representing Ghislaine Maxwell.
United States District Court, Southern District of New York
Court where the case is being heard.
United States Government
Prosecution party in the case.

Timeline (4 events)

2021-08-24
Parties conferred about the government's August 18 letter but failed to reach an agreement.
Teleconference
Government Counsel Defense Counsel
2021-10-11
Deadline for government to disclose co-conspirator statements, witness list, and proposed exhibit list.
USDC SDNY
Government
2021-10-18
Deadline for parties to file motions in limine.
USDC SDNY
Government Defense
2021-10-25
Deadline for responses to motions in limine (advanced from Nov 1).
USDC SDNY
Government Defense

Locations (1)

Location Context
Address of the United States District Court.

Relationships (2)

Ghislaine Maxwell Alleged Co-Conspirators Jeffrey Epstein
Document discusses 'co-conspirator statements' government intends to offer, specifically naming Jeffrey Epstein.
Jeffrey Epstein Employer/Employee Unnamed Employee
Referenced as 'the employee of Epstein’s' in the S2 Indictment.

Key Quotes (4)

"The government first attempts to walk back its multiple concessions regarding disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment."
Source
EFTA00029590.pdf
Quote #1
"The government’s objection is, in substance, a motion to reconsider."
Source
EFTA00029590.pdf
Quote #2
"The government says that, at least as of August 18, it intends to seek admission of co-conspirator statements from only two individuals: Jeffrey Epstein and the employee of Epstein’s referenced in paragraph 25(d) of the S2 Indictment."
Source
EFTA00029590.pdf
Quote #3
"If the government does not disclose what co-conspirator statements it intends to offer... Ms. Maxwell will be unable to file a motion in limine... challenging the admissibility of the co-conspirator statements."
Source
EFTA00029590.pdf
Quote #4

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