DOJ-OGR-00019579.jpg
519 KB
Extraction Summary
5
People
1
Organizations
1
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
519 KB
Summary
This legal document is a letter dated August 24, 2020, from Jeffrey S. Pagliuca to The Honorable Alison J. Nathan. The letter argues that his client, Ms. Maxwell, has demonstrated good cause to present a discrete set of sealed materials to judicial officers, countering that any argument of compromising grand jury secrecy is 'absurd'. Pagliuca asserts that the government has failed to provide a valid reason for withholding this information from other judicial officers.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The recipient of the letter, presumably a judge.
|
| Ms. Maxwell |
A party in a legal proceeding who seeks to disclose sealed materials to judicial officers.
|
|
| Jeffrey S. Pagliuca |
The author and signatory of the letter.
|
|
| Kerik |
A party in a cited legal case (Kerik, 2014 WL 12710346).
|
|
| Amodeo |
A party in a cited legal case (United States v. Amodeo, 44 F.3d 141).
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned as having obtained an ex parte order to subpoena information and has not articulated a reason for keeping i...
|
Timeline (2 events)
2020-08-24
Jeffrey S. Pagliuca sent a letter to Judge Alison J. Nathan arguing on behalf of Ms. Maxwell's request to disclose sealed materials.
prior to 2020-08-24
The Government obtained an ex parte order to subpoena information related to the Civil Litigation involving Ms. Maxwell.
Government
Ms. Maxwell's opponent
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a legal citation (Southern District of New York).
|
Relationships (3)
Jeffrey S. Pagliuca is writing on behalf of Ms. Maxwell, arguing for her request to be granted, suggesting an attorney-client relationship.
The document explicitly refers to an 'opponent in the Civil Litigation'.
The letter argues against the government's position, stating 'The government has not articulated a cogent reason for that information to be kept from the other judicial officers.'
Key Quotes (1)
"‘relevant to the performance of the judicial function and useful in the judicial process.’"Source
— Kerik, 2014 WL 12710346 (quoting United States v. Amodeo)
(A legal standard for what constitutes a judicial document, cited in the letter.)
DOJ-OGR-00019579.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,226 characters)
Case 1:20-cr-00330-AJN Document 25-10 Filed 08/26/20 Page 6 of 15
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,
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
App.120
DOJ-OGR-00019579
DOJ-OGR-00019579
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