DOJ-OGR-00019321.jpg
790 KB
Extraction Summary
5
People
4
Organizations
5
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
790 KB
Summary
This is a letter dated August 10, 2020, from Ghislaine Maxwell's attorney, Laura A. Menninger, to Judge Loretta A. Preska. The letter informs the court about newly discovered information that is critical to both Maxwell's civil case (Giuffre v. Maxwell) and her separate criminal case. Counsel explains they are currently barred from disclosing this information due to a protective order in the criminal case but intend to seek a modification of that order to share the details with the court.
People (5)
| Name | Role | Context |
|---|---|---|
| Laura A. Menninger | Counsel for Ms. Maxwell |
Author of the letter, representing Ghislaine Maxwell.
|
| Honorable Loretta A. Preska | Judge |
Recipient of the letter, presiding over the case Giuffre v. Ghislaine Maxwell in the United States District Court, So...
|
| Giuffre | Plaintiff |
A party in the civil case Giuffre v. Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
The client of the letter's author, and a defendant in both the civil case Giuffre v. Ghislaine Maxwell and the crimin...
|
| Judge Nathan | Judge |
A judge presiding over the Criminal Action (U.S. v. Maxwell) who issued a Protective Order.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. | company |
The law firm that Laura A. Menninger works for, as indicated in the letterhead.
|
| United States District Court, Southern District of New York | government agency |
The court where Judge Preska presides and where the civil action is being heard.
|
| Second Circuit | government agency |
A court mentioned as reviewing the unsealing order of July 23, 2020.
|
| U.S. Attorney’s Office | government agency |
An office with which Ms. Maxwell's counsel conferred regarding a modification of a Protective Order.
|
Timeline (3 events)
2020-07-23
The Court issued an unsealing order which is under review by the Second Circuit.
United States District Court, Southern District of New York
Court
2020-08-03
The Court issued an Order (Doc. 1069) and an Order and Protocol for Unsealing Decided Motions (Doc. 1044).
United States District Court, Southern District of New York
Court
2020-08-07
Counsel for Ms. Maxwell learned of critical new information that impacts both the civil action (Giuffre v. Maxwell) and the criminal action (U.S. v. Maxwell).
counsel for Ms. Maxwell
Locations (5)
| Location | Context |
|---|---|
|
The address of the law firm Haddon, Morgan and Foreman, P.C.
|
|
|
The location of the law firm Haddon, Morgan and Foreman, P.C.
|
|
|
The jurisdiction of the United States District Court mentioned in the letter.
|
|
|
The address of the United States District Court, Southern District of New York.
|
|
|
The location of the United States District Court.
|
Relationships (2)
The letter identifies Laura A. Menninger as "counsel for Ms. Maxwell".
They are opposing parties in the civil case titled "Giuffre v. Ghislaine Maxwell".
Key Quotes (2)
"for any civil proceeding or any purpose other than the defense"Source
— Protective Order, 20 Cr. 330 (AJN)
(A quote from a protective order in the Criminal Action, forbidding the use of certain information.)
DOJ-OGR-00019321.jpg
Quote #1
"further order of the Court"Source
— Protective Order, 20 Cr. 330 (AJN)
(A quote from a protective order in the Criminal Action, stating the condition under which information could be used.)
DOJ-OGR-00019321.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,366 characters)
Case 1:15-cv-07433-LAP Document 1100-2 Filed 08/10/20 Page 1 of 3
HADDON
MORGAN
FOREMAN
MORGAN
FOREMAN
Haddon, Morgan and Foreman, P.C
Laura A. Menninger
Laura A. Menninger
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
LMenninger@hmflaw.com
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
LMenninger@hmflaw.com
August 10, 2020
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: August 3, 2020 Order (Doc. 1096)
Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP)
Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP)
Dear Judge Preska:
I write in response to the Court’s Order of August 3, 2020 (Doc. 1069), the Order and Protocol for Unsealing Decided Motions (Doc. 1044) (“Protocol”), and to raise with the Court the legal effect of new information that came to the attention of counsel for Ms. Maxwell on Friday, August 7, 2020.
New information: On Friday, August 7, 2020, counsel for Ms. Maxwell learned of critical new information that impacts both this action and U.S. v. Maxwell, 20 Cr. 330 (AJN) (the “Criminal Action”). The information implicates Ms. Maxwell’s right to due process and fairness in this civil action and affects the Second Circuit’s review of the Court’s unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed under the Fourth, Fifth and Sixth Amendments.
Counsel makes the representations about implications of the new information as an officer of this Court. At this time, counsel is not at liberty to disclose the information because it is subject to a protective order in the Criminal Action, which forbids its use “for any civil proceeding or any purpose other than the defense” of the criminal action absent “further order of the Court.” Protective Order, 20 Cr. 330 (AJN) at ¶¶ 1(a), 18 (Exhibit A). As required by that Protective Order and Judge Nathan’s Individual Practices in Criminal Cases, counsel initiated a conferral with the U.S. Attorney’s Office over the weekend concerning a modification of the Protective Order to share the information with this Court and the Second Circuit. Barring agreement, Ms. Maxwell intends to seek modification of the Protective Order in the Criminal Action from Judge Nathan forthwith to permit sharing the information with this Court, ex parte and in camera if necessary, and with the Second Circuit (likewise under seal if necessary).
DOJ-OGR-00019321
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document