DOJ-OGR-00001756.jpg
776 KB
Extraction Summary
3
People
2
Organizations
0
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
776 KB
Summary
This legal document is page 5 of a filing on behalf of Ms. Maxwell to Judge Alison J. Nathan, dated August 17, 2020. The filing argues that the government has violated the spirit of a Protective Order by its handling of discovery materials, particularly in relation to their potential use in civil litigation and a grand jury investigation. The defense cites previous assurances from the government and a letter from Alex Rossmiller, which the Court relied upon, to argue that a new request should be granted by the Court.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The document is addressed to The Honorable Alison J. Nathan, indicating she is the judge presiding over the case.
|
| Ms. Maxwell | Defendant/Accused |
Referred to as the accused in the case, whose rights are impacted by a Protective Order. She is the client of the cou...
|
| Alex Rossmiller | Unknown |
Author of a letter dated July 28, 2020, which is cited in the document regarding assurances about the use of material...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
The judicial body that issued the Protective Order, received representations from the government, and is being asked ...
|
| government | Government agency |
The opposing party to Ms. Maxwell in the legal case, responsible for providing discovery materials and making represe...
|
Timeline (3 events)
2020-08-17
This document, a request concerning a Protective Order, was addressed to Judge Alison J. Nathan.
Court
Counsel for Ms. Maxwell
An on-going grand jury investigation by the government is mentioned.
Relationships (3)
The document is written by 'Counsel for Ms. Maxwell' on her behalf, discussing her rights as the accused.
The document details a dispute between Ms. Maxwell's defense and the government regarding the terms of a Protective Order in a criminal case.
The document is a filing addressed to Judge Nathan, asking her to rule on a request related to the case.
Key Quotes (3)
"for any civil proceeding or any purpose other than the defense of this action"Source
— The Protective Order
(Describing the prohibited uses of discovery materials under the Protective Order.)
DOJ-OGR-00001756.jpg
Quote #1
"the Government rarely provides any third party, including a witness, with any material they did not already possess,"Source
— the government
(An assurance made by the government to the Court regarding the distribution of discovery materials.)
DOJ-OGR-00001756.jpg
Quote #2
"concerns defense counsel raises about future use in civil litigation are not likely to occur."Source
— Alex Rossmiller
(A statement from a letter (Doc. #33) that the Court relied upon in a previous ruling.)
DOJ-OGR-00001756.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,995 characters)
Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 5 of 8
The Honorable Alison J. Nathan
August 17, 2020
Page 5
August 17, 2020
Page 5
parte application. [REDACTED] denied the application. [REDACTED].
Counsel for Ms. Maxwell then learned, [REDACTED]
The pressing issue that necessitates the filing of this request concerns [REDACTED]
These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt.
These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt.
The Protective Order in this case
The Protective Order in this case prohibits the use of the discovery materials or confidential-designated materials “for any civil proceeding or any purpose other than the defense of this action” absent mutual agreement in writing between the government and defense counsel or if “modified by further order of the Court.” Doc. # 36 at ¶¶ 1(a), 10(a), 18. Ms. Maxwell agreed to that limitation after assurances by the government, consistent with their representation to this Court, that “the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.” Letter of Alex Rossmiller at 6 (Doc. # 33) (July 28, 2020). This Court relied on that representation in its ruling that government witnesses should not be limited in their use of materials gained from the government in any related civil litigation. Memorandum Op’n & Order at 3 (July 30, 2020). Yet as described above, the government must have given a copy of the sealed order to [REDACTED]
The Protective Order in this case prohibits the use of the discovery materials or confidential-designated materials “for any civil proceeding or any purpose other than the defense of this action” absent mutual agreement in writing between the government and defense counsel or if “modified by further order of the Court.” Doc. # 36 at ¶¶ 1(a), 10(a), 18. Ms. Maxwell agreed to that limitation after assurances by the government, consistent with their representation to this Court, that “the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.” Letter of Alex Rossmiller at 6 (Doc. # 33) (July 28, 2020). This Court relied on that representation in its ruling that government witnesses should not be limited in their use of materials gained from the government in any related civil litigation. Memorandum Op’n & Order at 3 (July 30, 2020). Yet as described above, the government must have given a copy of the sealed order to [REDACTED]
Paragraph 18 of the Protective Order permits modification by the Court. Further, any concerns that the government may raise concerning their on-going grand jury investigation will be obviated by submission of these materials under seal in the other matters.
The reasons this Court should grant the request
[REDACTED]
[REDACTED]
7 [REDACTED]
DOJ-OGR-00001756
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