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Extraction Summary

3
People
3
Organizations
0
Locations
1
Events
1
Relationships
4
Quotes

Document Information

Type: Legal filing / letter motion (defense reply)
File Size: 945 KB
Summary

This document is page 5 of a legal filing (Case 1:20-cr-00330-AJN) dated August 24, 2020, addressed to Judge Alison J. Nathan. It argues that Protective Orders can be modified as circumstances change and asserts that Ms. Maxwell did not waive her right to seek modification. The text claims the government circumvented Second Circuit processes regarding civil materials for grand jury use and cites various case laws supporting the court's power to modify protective orders.

People (3)

Name Role Context
Alison J. Nathan Judge
Recipient of the letter, addressed as 'The Honorable'
Ghislaine Maxwell Defendant
Subject of the legal arguments regarding protective orders; referred to as 'Ms. Maxwell'
Defense Counsel Author (Implied)
Refers to 'defense counsel has located'

Organizations (3)

Name Type Context
Second Circuit
Court of Appeals mentioned regarding processes for grand jury investigations
The Government
Prosecution/DOJ, opposing party in the motion
Department of Justice (DOJ)
Indicated by footer 'DOJ-OGR-00001767'

Timeline (1 events)

2020-09-08
Document Filed with the court
Court

Relationships (1)

Ghislaine Maxwell Adversarial/Legal The Government
Defense arguing against government suggestions regarding protective orders.

Key Quotes (4)

"Protective Orders May Be Modified As Circumstances Change"
Source
DOJ-OGR-00001767.jpg
Quote #1
"Ms. Maxwell somehow waived her ability to seek modification by agreeing to a Protective Order before she knew what was contained in the criminal discovery"
Source
DOJ-OGR-00001767.jpg
Quote #2
"the Second Circuit has outlined a process for the government to seek civil materials subject to protective orders for use in grand jury investigations, a process the government circumvented."
Source
DOJ-OGR-00001767.jpg
Quote #3
"That Ms. Maxwell did not know what was in the sealed materials before she signed the Protective Order, or proposed a draft, is self-evident."
Source
DOJ-OGR-00001767.jpg
Quote #4

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