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Extraction Summary

4
People
6
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes

Document Information

Type: Legal correspondence / court filing (reply letter)
File Size: 800 KB
Summary

This is page 2 of a legal letter addressed to Judge Alison J. Nathan, dated August 24, 2020, filed in the case of United States v. Ghislaine Maxwell. The defense argues against the government's characterization of Maxwell's actions as 'cherry-picking' and challenges the government's issuance of subpoenas as not being 'standard practice,' citing Second Circuit case law (Martindell) regarding protective orders and civil discovery. Large portions of the document are redacted.

People (4)

Name Role Context
Alison J. Nathan Judge
Addressee of the letter (The Honorable).
Ghislaine Maxwell Defendant
Subject of the legal defense; accused by the government of cherry-picking materials.
Judge Koeltl Judge
Cited for a previous legal opinion regarding government investigative powers.
Don King Litigant (Cited Case)
Mentioned in case citation Botha v. Don King Prods.

Organizations (6)

Name Type Context
The Government
The opposing party in the criminal case; accused of improper subpoena practices.
Second Circuit
Court of Appeals whose rulings are cited as controlling authority.
International Telephone & Telegraph Corp.
Part of cited case Martindell v. Int’l Telephone & Telegraph Corp.
Don King Prods., Inc.
Part of cited case Botha v. Don King Prods., Inc.
Minpeco S.A.
Part of cited case Minpeco S.A. v. Conticommodity Servs., Inc.
Department of Justice (DOJ)
Implied by the Bates stamp 'DOJ-OGR-00001764'.

Timeline (2 events)

August 24, 2020
Submission of legal letter to Judge Nathan
Court (S.D.N.Y.)
Defense Counsel Judge Nathan
Prior to August 24, 2020
Issuance of subpoenas by the government
Unknown

Locations (1)

Location Context
Southern District of New York, mentioned in case citations.

Relationships (1)

Ghislaine Maxwell Adversarial The Government
Legal arguments regarding defense motions and government accusations.

Key Quotes (4)

"The government’s ad hominem suggestion that Ms. Maxwell has “cherry-pick[ed] materials” to seek an “advantage in their efforts to defend against accusations of abuse”... reveals a fundamental (or feigned) lack of understanding"
Source
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Quote #1
"Ms. Maxwell simply seeks to alert the judicial officers in the related Civil Litigation to facts about which her adversary is already aware."
Source
DOJ-OGR-00001764.jpg
Quote #2
"Second, the government tries to normalize, without citation to authority, its conduct as “standard practice.”"
Source
DOJ-OGR-00001764.jpg
Quote #3
"the Second Circuit has made clear that the Government may not use its ‘awesome’ investigative powers to seek modification of a protective order merely to compare the fruits of the plaintiff’s discovery in a civil action with the results of a prosecutorial investigation in a criminal action."
Source
DOJ-OGR-00001764.jpg
Quote #4

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