EFTA00026750.pdf

1.63 MB
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Extraction Summary

9
People
4
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence / proposed protective order
File Size: 1.63 MB
Summary

This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The Government argues for the entry of its proposed protective order regarding discovery materials, specifically opposing the defendant's request to publicly name victims who have previously spoken to the media and opposing restrictions on the Government's use of its own investigative materials. The document includes the full text of the proposed protective order, detailing how 'Confidential' and 'Highly Confidential' information (including sexualized imagery) must be handled by the defense.

People (9)

Name Role Context
Alison J. Nathan Judge
United States District Judge, Southern District of New York
Ghislaine Maxwell Defendant
Defendant in Case 1:20-cr-00330-AJN
Jeffrey Epstein Deceased Co-conspirator
Referenced in relation to victims and previous litigation (19 Cr. 490 (RMB))
Audrey Strauss Acting United States Attorney
Signatory of the letter
Alex Rossmiller Assistant United States Attorney
Signatory of the letter
Alison Moe Assistant United States Attorney
Signatory of the letter
Maurene Comey Assistant United States Attorney
Signatory of the letter
Corley Defendant in cited case
Cited in United States v. Corley regarding victim privacy
Kelly Defendant in cited case
Cited in United States v. Kelly regarding victim privacy

Organizations (4)

Name Type Context
U.S. Department of Justice
Government agency prosecuting the case
United States Attorney Southern District of New York
Prosecuting office
United States District Court Southern District of New York
Court where the case is filed
Bureau of Prisons
Agency responsible for providing defendant with electronic access to discovery

Timeline (2 events)

2020-07-09
Start of conferral period between Government and Defense regarding the protective order.
N/A
Government Defense Counsel
2020-07-28
Government submits letter and proposed protective order to Judge Nathan.
SDNY
Government Judge Nathan

Relationships (2)

Ghislaine Maxwell Co-conspirators / Associates Jeffrey Epstein
Document refers to 'victims of Ghislaine Maxwell and Jeffrey Epstein' and their joint legal history.
Ghislaine Maxwell Adversarial United States of America
Maxwell is the Defendant in the criminal case prosecuted by the USA.

Key Quotes (4)

"The defendant’s demand that she and her counsel be permitted to name any individuals who have ever publicly identified themselves as a victim of either Epstein or the defendant in any 'public fora,' and at any time, without limitation, is extraordinarily broad, unnecessary, and inappropriate, and should be denied."
Source
EFTA00026750.pdf
Quote #1
"The Crime Victims' Rights Act, 18 U.S.C. § 3771, requires district courts to implement procedures to ensure that crime victims are accorded, among other rights, '[t]he right to be reasonably protected from the accused,' in addition to '[t]he right to be treated with fairness and with respect for the victim’s dignity and privacy.'"
Source
EFTA00026750.pdf
Quote #2
"Indeed, it is nonsensical for a protective order to require limitations of the Government in its use of material already in its possession so that the Government may provide a defendant with discovery."
Source
EFTA00026750.pdf
Quote #3
"Highly Confidential Information contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals."
Source
EFTA00026750.pdf
Quote #4

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