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EFTA00027165.pdf

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Extraction Summary

6
People
2
Organizations
0
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Email chain
File Size: 86.9 KB
Summary

This document is an email chain from April 22, 2021, concerning the case US v. Maxwell. The initial email features Laura Menninger, defense counsel for Ghislaine Maxwell, submitting a Letter Motion for an adjournment of the trial to Judge Nathan and requesting redactions to protect client confidentiality under Rule 1.6. Subsequent emails show internal coordination among USANYS prosecutors drafting a response to this motion, which was due by 5 PM that day.

People (6)

Name Role Context
Laura Menninger Partner, Haddon, Morgan & Foreman, P.C.
Defense attorney for Ghislaine Maxwell sending a letter motion to the Judge.
Judge Nathan Judge
Addressed in the email from Laura Menninger regarding the adjournment request.
Jeff Pagliuca Attorney
CC'd on the email from Laura Menninger.
Bobbi Sternheim Attorney
CC'd on the email from Laura Menninger.
Nicole Simmons Attorney
CC'd on the email from Laura Menninger.
Ghislaine Maxwell Defendant
Subject of the case 'US v. Maxwell'; referred to as 'Ms. Maxwell'.

Organizations (2)

Name Type Context
USANYS
United States Attorney for the Southern District of New York; prosecutors discussing the response.
Haddon, Morgan & Foreman, P.C.
Law firm representing Ghislaine Maxwell.

Timeline (2 events)

2021-04-22
Defense counsel Laura Menninger submits a Letter Motion for an Adjournment of the trial in US v. Maxwell.
Court (via email)
Laura Menninger Judge Nathan
View
2021-04-22
US Attorney's Office (USANYS) drafts a response to the adjournment request, noting a deadline of 5 PM.
Internal Email
USANYS Staff
View

Relationships (2)

Laura Menninger → Attorney-Client → Ghislaine Maxwell
Laura Menninger identifies as 'Counsel for Ms. Maxwell' in the email.
Laura Menninger → Co-Counsel/Colleagues → Jeff Pagliuca
Copied on the same legal correspondence representing the defense.

Key Quotes (3)

"Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an Adjournment of the trial."
Source
EFTA00027165.pdf
Quote #1
"Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a client even where that information is publicly available."
Source
EFTA00027165.pdf
Quote #2
"FYI. Our response is due at 5 today."
Source
EFTA00027165.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,714 characters)

From: [REDACTED] (USANYS)" <[REDACTED]>
To: [REDACTED] <[REDACTED]>; [REDACTED] (USANYS)" <[REDACTED]>
Cc: [REDACTED] (USANYS)" <[REDACTED]>; [REDACTED]
Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Date: Thu, 22 Apr 2021 19:06:28 +0000
Attachments: 2021-04-22_Gov't_letter_re_GM_request_for_adjournment_v3.docx.rd.docx
Thanks [REDACTED], this is well done, and my edits are attached. As you'll see, I suggested [REDACTED]
[REDACTED]
Happy to look at another version before filing, thanks very much.
From: [REDACTED]
Sent: Thursday, April 22, 2021 1:32 PM
To: [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED]
Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Draft response attached.
From: [REDACTED]
Sent: Thursday, April 22, 2021 12:14 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] (USANYS) <[REDACTED]>
Subject: FW: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
FYI. Our response is due at 5 today.
From: Laura Menninger <[REDACTED]>
Sent: Thursday, April 22, 2021 11:22 AM
To: [REDACTED]
Cc: [REDACTED]; [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED]; Jeff Pagliuca <[REDACTED]>; 'Bobbi Sternheim' <[REDACTED]>; Nicole Simmons <[REDACTED]>
Subject: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Judge Nathan -
Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an Adjournment of the trial.
Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule 1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex rel. Okla. Bar Ass'n v. McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the representation, whatever its source").
Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.
Best regards,
Laura Menninger
Laura A. Menninger | Partner
Haddon, Morgan & Foreman, P.C.
[REDACTED]
[REDACTED]
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