DOJ-OGR-00001719.jpg

858 KB

Extraction Summary

3
People
4
Organizations
5
Locations
4
Events
3
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 858 KB
Summary

This legal document is a letter dated August 13, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution is opposing recent requests from the defendant, Ghislaine Maxwell, for an early disclosure of government witnesses and for the court to intervene with the Bureau of Prisons. The government argues these requests are premature and meritless, citing the early stage of discovery and previous denials of similar applications by the court.

People (3)

Name Role Context
Alison J. Nathan The Honorable, United States District Judge
Recipient of the letter, addressed as "Dear Judge Nathan".
Ghislaine Maxwell Defendant
The defendant in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).
Silvio J. Mollo
The name of the building where the U.S. Attorney's office is located.

Organizations (4)

Name Type Context
U.S. Department of Justice government agency
The entity sending the letter, as indicated by the letterhead.
United States Attorney, Southern District of New York government agency
The specific office within the Department of Justice sending the letter.
United States District Court, Southern District of New York court
The court where Judge Alison J. Nathan presides and where the case is filed.
Bureau of Prisons government agency
Mentioned in relation to the defendant's request for the Court to intervene in its protocols and inmate determinations.

Timeline (4 events)

2020-07-23
The Court issued an order (Dkt. 28) denying the defendant's request to prohibit extrajudicial statements.
United States District Court, Southern District of New York
The Court Ghislaine Maxwell U.S. Government
2020-07-30
The Court issued an order (Dkt. 37) denying the defendant's application for a protective order that would allow the defense to publicly name victims.
United States District Court, Southern District of New York
The Court Ghislaine Maxwell
2020-08-10
The defendant, Ghislaine Maxwell, submitted a letter to the court with two requests.
United States District Court, Southern District of New York
Ghislaine Maxwell The Court
2020-08-13
The U.S. Government filed a letter in opposition to the defendant's requests.
United States District Court, Southern District of New York
U.S. Department of Justice The Honorable Alison J. Nathan

Locations (5)

Location Context
The address of the United States Attorney's office.
The address of the United States Attorney's office.
The location of the United States District Court.
The address of the United States Courthouse.
The jurisdiction of the U.S. Attorney and the U.S. District Court mentioned.

Relationships (3)

U.S. Government adversarial (legal) Ghislaine Maxwell
The document is a letter from the U.S. Government arguing in opposition to legal motions made by the defendant, Ghislaine Maxwell, in the criminal case 'United States v. Ghislaine Maxwell'.
U.S. Government professional (legal) Alison J. Nathan
The U.S. Government, as the prosecution, is addressing Judge Nathan, the presiding judge, to argue its legal position.
Ghislaine Maxwell professional (legal) Alison J. Nathan
The document describes multiple applications and letters submitted by the defendant, Ghislaine Maxwell, to the Court, which is presided over by Judge Nathan.

Key Quotes (2)

"almost six weeks since"
Source
— Ghislaine Maxwell's defense (Quoted from the defendant's letter, arguing about the status of discovery production since her arrest.)
DOJ-OGR-00001719.jpg
Quote #1
"just now beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would begin as soon as the Court entered a protective order."
Source
— Ghislaine Maxwell's defense (Quoted from the defendant's letter (Def. Ltr. at 2), complaining about the pace of discovery from the Government.)
DOJ-OGR-00001719.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,572 characters)

Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
August 13, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant’s letter of August 10, 2020 (the “Defense Letter” or “Def. Ltr.”), requesting that the Court order the Government to disclose the names of certain Government witnesses 11 months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied.
A. The Defendant’s Demand That the Government Name Certain Trial Witnesses
For the third time in as many weeks, the defendant and her counsel have applied to the Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28) (denying the defendant’s request that the Court enter an order prohibiting the Government and attorneys for non-parties from making extrajudicial statements “concerning this case”); Order dated July 30, 2020 (Dkt. 37) (denying the defendant’s application for a protective order that would allow the defense to publicly name and identify victims). In the defendant’s most recent application, she asks the Court to order that the Government disclose a partial witness list, in the form of identifying certain victims referenced in the Superseding Indictment (the “Indictment”), fully 11 months prior to trial. This request is at best premature given that the production of discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have had no discussions about—let alone asked the Court to set—a schedule for pretrial disclosures, including for witness lists and 3500 material.
In the first instance, the defendant complains about the status of discovery production, arguing that “almost six weeks since” the arrest of the defendant, the Government is “just now beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would begin as soon as the Court entered a protective order.” Def. Ltr. at 2. The suggestion that the Government somehow delayed that initial production is nonsense. As the Court is aware, the
DOJ-OGR-00001719

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