DOJ-OGR-00005262.jpg

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Extraction Summary

6
People
4
Organizations
3
Locations
4
Events
2
Relationships
3
Quotes

Document Information

Type: Legal filing / court document (letter motion)
File Size: 623 KB
Summary

This document is page 3 of a legal filing dated October 18, 2021, addressed to Judge Alison J. Nathan regarding the case of Ghislaine Maxwell. The defense argues they have received voluminous discovery materials (over 14,000 pages) from the government very recently (Oct 11-12), leaving insufficient time to review them before filing motions in limine. The document details the logistics of the hard drive deliveries to counsel in New York and Colorado, and to Ms. Maxwell at the MDC, while noting that some materials provided to Maxwell were incomplete.

People (6)

Name Role Context
Alison J. Nathan Judge
Addressee of the letter ('The Honorable')
Ghislaine Maxwell Defendant
Referred to as 'Ms. Maxwell'; received hard drive late; held at MDC
Mr. Pagliuca Defense Counsel
Quoted in footnote regarding motion schedules during arraignment
Ms. Comey Prosecutor / Government Counsel
Quoted in footnote regarding supplemental motions
New York counsel Defense Team
Picked up hard drives from U.S. Attorney's Office
Colorado counsel Defense Team
Received hard drives via Federal Express

Organizations (4)

Name Type Context
U.S. Attorney’s Office
Source of the discovery hard drives
Federal Express
Courier service used to deliver hard drives to Colorado counsel
MDC
Metropolitan Detention Center; location where Maxwell is held and legal mail was deposited
DOJ
Department of Justice (referenced in footer DOJ-OGR-00005262)

Timeline (4 events)

2021-04-23
Arraignment where scheduling issues were discussed (referenced in footnote).
Court
2021-10-11
Government produced Jencks Act and Giglio material and exhibit list.
New York
Government Defense Counsel
2021-10-12
Colorado counsel received hard drives via FedEx.
Colorado
2021-10-14
Ms. Maxwell received her hard drive (missing some .pdf disclosures).
MDC
Ms. Maxwell

Locations (3)

Location Context
Location of U.S. Attorney's Office and local counsel
Location of remote counsel
MDC
Detention center where Maxwell received materials

Relationships (2)

Ms. Maxwell Attorney-Client Mr. Pagliuca
Pagliuca arguing on behalf of the defense schedule in the context of Maxwell's case.
Ms. Comey Prosecutor/Employee U.S. Attorney’s Office
Comey representing the government's position in court transcripts.

Key Quotes (3)

"approximately 6,000 pages on “non-testifying” witness materials, the bulk of which is exculpatory"
Source
DOJ-OGR-00005262.jpg
Quote #1
"Counsel have been unable to thoroughly review and analyze this voluminous production in sufficient time"
Source
DOJ-OGR-00005262.jpg
Quote #2
"[W]e don’t think it’s tenable to stick to the motion in limine schedule based on the government’s proposed disclosures."
Source
DOJ-OGR-00005262.jpg
Quote #3

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