DOJ-OGR-00005263.jpg
528 KB
Extraction Summary
3
People
2
Organizations
0
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
528 KB
Summary
This legal document is a letter dated October 18, 2021, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan on behalf of his client, Ms. Maxwell. Pagliuca argues that due to recent government disclosures and a cumbersome two-step file encryption process implemented by the government, there has been insufficient time to meet the deadline for filing motions *in limine*. Citing a previous court order, he reserves the right for the defense to file additional or supplemental motions after the deadline has passed.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The recipient of the letter, presumably the judge presiding over the case.
|
| Maxwell | Defendant/Client |
Referred to as 'Ms. Maxwell', she is the subject of the legal filing, whose counsel is arguing for more time.
|
| Jeffrey S. Pagliuca | Counsel |
The author of the letter, submitting it on behalf of Ms. Maxwell.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| the Court | government agency |
Mentioned as a party with whom concerns were previously raised and as the entity that issued a previous order.
|
| the government | government agency |
The opposing party in the legal case, responsible for disclosures and encrypting files.
|
Timeline (3 events)
2021-10-11
The government's disclosure of Jencks Act, Giglio material and government exhibits.
2021-10-18
The deadline to prepare and submit additional filings (motions in limine).
Relationships (2)
Pagliuca is identified as Ms. Maxwell's counsel and is submitting the legal document on her behalf.
The document describes a legal case where the government is providing disclosures (as the prosecution) to Maxwell's counsel (the defense).
Key Quotes (2)
"In addition, and as requested by the parties, the parties may bring issues to the Court's attention that arise after the deadline for motions in limine if the issues could not have been raised within the deadline set for in limine motions."Source
— 6/2/2021 Order (Dkt. 297)
(Quoted from a previous court order to support the request to file motions after the deadline.)
DOJ-OGR-00005263.jpg
Quote #1
"This two-step process has slowed the review process."Source
— Jeffrey S. Pagliuca
(From a footnote explaining how the government's encryption method for discovery files has created delays for the defense.)
DOJ-OGR-00005263.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,532 characters)
Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 4 of 4
The Honorable Alison J. Nathan
October 18, 2021
Page 4
October 18, 2021
Page 4
Maxwell had sufficient opportunity to review the disclosures or the opportunity to effectively review and discuss the production with counsel. Clearly, there has been insufficient time to prepare any additional filings to meet today's deadline, a concern previously raised with government counsel and the Court.²
Accordingly, Ms. Maxwell reserves the right to file additional/or supplemental motions in limine in response to the government's recent disclosure of Jencks Act, Giglio material and government exhibits, dated October 11, 2021. See 6/2/2021 Order (Dkt. 297) (“In addition, and as requested by the parties, the parties may bring issues to the Court's attention that arise after the deadline for motions in limine if the issues could not have been raised within the deadline set for in limine motions.”).
Your consideration is greatly appreciated.
Respectfully Submitted,
[Signature]
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
² In addition, Ms. Maxwell's counsel provided the government with encrypted hard drives to obviate the need for the government to encrypt the underlying files. Contrary to the defense's specific request, the government encrypted the files themselves necessitating two passcodes—one to open the hard drive and one to open the files—to access the documents each time we wish to review them. This two-step process has slowed the review process.
DOJ-OGR-00005263
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