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351 KB

Extraction Summary

7
People
2
Organizations
1
Locations
1
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 351 KB
Summary

This is the final page of a legal document (Document 528) filed on December 6, 2021, in the Southern District of New York. The United States Attorney, Damian Williams, and his assistants conclude their argument by requesting the Court to preclude testimony from "Jane's counsel." They argue that allowing such testimony would compel a witness named Glassman to provide extensive context beyond existing notes, thereby exceeding the scope of any privilege waiver.

People (7)

Name Role Context
Glassman
Mentioned as a potential witness whose testimony would need to go beyond notes and could involve privilege waiver.
Jane
Mentioned in the context of "Jane's counsel," suggesting she is a party to the legal case.
DAMIAN WILLIAMS United States Attorney
Listed as the United States Attorney submitting the document.
Maurene Comey Assistant United States Attorney
Listed as one of the Assistant United States Attorneys on the filing.
Alison Moe Assistant United States Attorney
Listed as one of the Assistant United States Attorneys on the filing.
Lara Pomerantz Assistant United States Attorney
Listed as one of the Assistant United States Attorneys on the filing.
Andrew Rohrbach Assistant United States Attorney
Listed as one of the Assistant United States Attorneys on the filing.

Organizations (2)

Name Type Context
United States Attorney government agency
The office of DAMIAN WILLIAMS, representing the government in the case.
Southern District of New York government agency
The jurisdiction for the Assistant United States Attorneys who filed the document.

Timeline (1 events)

2021-12-06
The United States Attorney's office filed Document 528 in case 1:20-cr-00330-PAE.
Southern District of New York

Locations (1)

Location Context
The location of the court and the jurisdiction of the U.S. Attorneys.

Relationships (1)

United States Attorney's Office professional Jane's counsel
The document shows an adversarial legal relationship, with the U.S. Attorney's office filing a motion to prevent testimony from Jane's counsel.

Key Quotes (1)

"For the foregoing reasons, the Court should preclude testimony by Jane’s counsel."
Source
— DAMIAN WILLIAMS, United States Attorney (The concluding sentence of the legal argument, summarizing the request made in the document.)
DOJ-OGR-00008244.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (746 characters)

Case 1:20-cr-00330-PAE Document 528 Filed 12/06/21 Page 8 of 8
the context in which it was made. Indeed, that statement is one of several in the notes, and to avoid misleading the jury, Glassman would also have to describe and provide context to the remaining points reflected in the note. Doing all this would require Glassman to go well beyond the notes, exceeding the scope of any privilege waiver.
III. Conclusion
For the foregoing reasons, the Court should preclude testimony by Jane’s counsel.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Maurene Comey
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (by ECF)
8
DOJ-OGR-00008244

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