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Extraction Summary

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

Document Information

Type: Legal correspondence (reply brief/letter motion)
File Size: 559 KB
Summary

This document is a legal reply from Ghislaine Maxwell's attorney, Jeffrey Pagliuca, to Judge Alison J. Nathan, dated August 24, 2020. It supports a request to modify a protective order to allow Maxwell to disclose to an adversary in a separate civil litigation that said adversary has already provided materials to the U.S. Attorney's Office via subpoena. The document argues against the government's stance that the civil litigation is unrelated and that disclosure would jeopardize the criminal investigation.

People (4)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the criminal case and the party requesting modification of a protective order.
Alison J. Nathan Judge
Recipient of the letter; United States District Court Judge.
Jeffrey Pagliuca Attorney
Sender of the letter; Attorney at Haddon, Morgan and Foreman, representing Maxwell.
[Redacted] Adversary
An adversary in a related Civil Litigation who handed materials to the U.S. Attorney's Office.

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
The court handling the case.
U.S. Attorney's Office
Prosecution; recipient of subpoenaed materials.

Timeline (3 events)

August 17, 2020
Proposed redactions to Request to Modify Protective Order filed by Ms. Maxwell.
New York, NY (SDNY)
August 18, 2020
Court Order (Doc. 44) referenced regarding filing procedures.
New York, NY (SDNY)
Judge Alison J. Nathan
August 24, 2020
Filing of Reply in Support of Request to Modify Protective Order.
New York, NY (SDNY)

Locations (2)

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

Relationships (2)

Ghislaine Maxwell Attorney-Client Jeffrey Pagliuca
Pagliuca is sending the letter on behalf of Defendant Maxwell from his law firm.
Ghislaine Maxwell Legal Adversary [Redacted Adversary]
Text refers to 'her adversary [REDACTED]' in the 'Civil Litigation'.

Key Quotes (4)

"Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to [REDACTED] (the 'Civil Litigation') the fact that her adversary [REDACTED] already handed over [REDACTED], to the U.S. Attorney’s Office pursuant to a subpoena"
Source
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Quote #1
"The government proposes to keep [REDACTED] in the dark about the fact and method of the disclosure."
Source
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Quote #2
"They claim the civil litigation is 'unrelated,' that issuance of the subpoena was 'standard practice,' and that disclosure will jeopardize an ongoing criminal investigation"
Source
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Quote #3
"First, the government claims the civil litigation is [REDACTED] Resp. at 1. The assertion is frivolous."
Source
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Quote #4

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