DOJ-OGR-00001768.jpg
507 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
507 KB
Summary
This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca argues on behalf of his client, Ms. Maxwell, for a limited request to present sealed materials to other judicial officers, asserting that the materials are judicial documents and that disclosure would not compromise grand jury secrecy. The letter contends that the government has failed to provide a sufficient reason to prevent this limited disclosure.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The recipient of the letter, presumably a judge.
|
| Ms. Maxwell | Party in litigation |
The individual on whose behalf the letter is written, seeking to disclose materials under seal.
|
| Kerik |
Mentioned in the case citation 'Kerik, 2014 WL 12710346'.
|
|
| Amodeo |
Mentioned in the case citation 'United States v. Amodeo, 44 F.3d 141'.
|
|
| Jeffrey S. Pagliuca |
The author of the letter, signing it.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as having obtained an ex parte order and as a party in the litigation.
|
| S.D.N.Y. | court |
Southern District of New York, mentioned in a case citation.
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| 2d Cir. | court |
Second Circuit Court of Appeals, mentioned in a case citation.
|
Timeline (2 events)
2020-08-24
Jeffrey S. Pagliuca sent a letter to The Honorable Alison J. Nathan regarding Ms. Maxwell's case.
The Government obtained an ex parte order to subpoena information.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a case citation, referring to the Southern District of New York.
|
Relationships (3)
Jeffrey S. Pagliuca is writing a legal letter on behalf of Ms. Maxwell, indicating he is likely her legal counsel.
The letter describes a legal dispute between Ms. Maxwell and the Government regarding the disclosure of information.
The document explicitly refers to 'Ms. Maxwell’s opponent in the Civil Litigation'.
Key Quotes (1)
"relevant to the performance of the judicial function and useful in the judicial process."Source
— Kerik, 2014 WL 12710346, at *1 (S.D.N.Y. July 23, 2014), (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995))
(Quoted from a legal precedent to define what constitutes 'judicial documents'.)
DOJ-OGR-00001768.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,228 characters)
Case 1:20-cr-00330-AJN Document 54 Filed 09/08/20 Page 6 of 6
The Honorable Alison J. Nathan
August 24, 2020
Page 6
August 24, 2020
Page 6
documents, that is, documents that are ‘relevant to the performance of the judicial function and useful in the judicial process.’” Kerik, 2014 WL 12710346, at *1 (S.D.N.Y. July 23, 2014), (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)).
The Materials that Ms. Maxwell seeks to disclose (to judicial officers under seal) are, without question, judicial documents. [REDACTED]
And, at a minimum, Ms. Maxwell’s opponent in the Civil Litigation knows both that the Government obtained an ex parte order to subpoena the information and what was produced. Accordingly, the argument that somehow grand jury secrecy will be compromised by disclosure, under seal to judicial officers reviewing the very material at issue, is absurd. Ms. Maxwell has demonstrated good cause for her very limited request to present a discrete set of sealed materials under seal to [REDACTED]
[REDACTED]
The government has not articulated a cogent reason for that information to be kept from the other judicial officers.
Sincerely,
[Signature]
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00001768
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