DOJ-OGR-00019338.jpg
749 KB
Extraction Summary
7
People
5
Organizations
2
Locations
0
Events
10
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
749 KB
Summary
This legal document, dated August 21, 2020, is a submission from the Acting United States Attorney and Assistant United States Attorneys to Honorable Alison J. Nathan. It argues against the defendant's application to use criminal discovery materials in civil cases, asserting that the application lacks legal justification, attempts to circumvent a protective order, and is irrelevant to the civil litigation. The document suggests the defendant's intent is to falsely accuse the Government and another party.
People (7)
| Name | Role | Context |
|---|---|---|
| Honorable Alison J. Nathan | Judge |
Addressee of the document
|
| AUDREY STRAUSS | Acting United States Attorney |
Signatory of the document
|
| Maurene Comey | Assistant United States Attorney |
Signatory of the document
|
| Alison Moe | Assistant United States Attorney |
Signatory of the document
|
| Lara Pomerantz | Assistant United States Attorney |
Signatory of the document
|
| defendant | Party in a legal case |
The party whose application is being opposed
|
| Recipient | Party in a legal case |
A party who the defendant is accused of falsely accusing
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Government | Government agency/entity |
A party in the legal case, also referred to as the entity issuing subpoenas and being attacked by the defendant
|
| United States Attorney | Government agency |
Office represented by the signatories
|
| Southern District of New York | Government jurisdiction/office |
Location of the United States Attorney's office
|
| Defense | Legal party/position |
Refers to the defendant's legal position or team
|
| Court | Judicial body |
The body adjudicating the cases and to which the document is addressed
|
Locations (2)
| Location | Context |
|---|---|
|
Location of the United States Attorney's office
|
|
|
Part of the address for the Southern District of New York
|
Relationships (10)
Judge and attorney submitting a filing to her
Judge and attorney submitting a filing to her
Judge and attorney submitting a filing to her
Judge and attorney submitting a filing to her
Acting United States Attorney and Assistant United States Attorney
Acting United States Attorney and Assistant United States Attorney
Acting United States Attorney and Assistant United States Attorney
The defendant is opposing the Government's position and is accused of attacking the Government
The defendant is accused of falsely accusing the Recipient
The defendant is accused of falsely accusing both the Recipient and the Government
Key Quotes (1)
"If anything, the Defense Letter suggests that the defendant intends to use criminal discovery materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those cases and made in a forum in which the Government is not a party and would have no opportunity to respond."Source
— AUDREY STRAUSS (and Assistant United States Attorneys)
(Footnote 6, explaining the perceived intent behind the defendant's application.)
DOJ-OGR-00019338.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,192 characters)
Case 1:20-cc-0330-AJN Document 420 Filed 08/21/20 Page 5 of 5
Honorable Alison J. Nathan
August 21, 2020
Page 5
Honorable Alison J. Nathan
August 21, 2020
Page 5
requested—the defendant can make such arguments, and the Government can and will vigorously
oppose them, at the appropriate stage in this case.
oppose them, at the appropriate stage in this case.
Finally, to the extent the defendant contends that the relief requested is somehow necessary
to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to
explain what legal argument she wishes to make in her Civil Cases based on the discovery
materials she has identified or what relevance those materials have to the litigation of the Civil
Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization
for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the
Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that
courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the
defendant identifies no specific reason why these materials are relevant to the issues pending in
those cases, other than to falsely accuse the Recipient and the Government of some sort of
malfeasance.⁶
to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to
explain what legal argument she wishes to make in her Civil Cases based on the discovery
materials she has identified or what relevance those materials have to the litigation of the Civil
Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization
for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the
Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that
courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the
defendant identifies no specific reason why these materials are relevant to the issues pending in
those cases, other than to falsely accuse the Recipient and the Government of some sort of
malfeasance.⁶
In sum, the defendant’s arguments in favor of her application offer no explanation of the
relevant legal theory the materials would support, not to mention a compelling reason for this Court
to permit an end-run around the protective order and permit the use of criminal discovery to litigate
a civil case. Accordingly, the application in the Defense Letter should be denied.
relevant legal theory the materials would support, not to mention a compelling reason for this Court
to permit an end-run around the protective order and permit the use of criminal discovery to litigate
a civil case. Accordingly, the application in the Defense Letter should be denied.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
Acting United States Attorney
By: ______________/s
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All counsel of record, via ECF
⁶ If anything, the Defense Letter suggests that the defendant intends to use criminal discovery
materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those
cases and made in a forum in which the Government is not a party and would have no opportunity
to respond.
materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those
cases and made in a forum in which the Government is not a party and would have no opportunity
to respond.
DOJ-OGR-00019338
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