DOJ-OGR-00001811.jpg
833 KB
Extraction Summary
7
People
4
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
833 KB
Summary
This legal document is a letter from defense counsel Jeffrey S. Pagliuca to Judge Alison J. Nathan, dated October 23, 2020, concerning Ghislaine Maxwell's case. The letter complains that the Bureau of Prisons (BOP) and the Metropolitan Detention Center (MDC) are severely hindering Ms. Maxwell's ability to prepare her defense by preventing counsel from reviewing documents with her effectively during legal visits. The defense requests the Court to order the BOP to allow them to pass legal papers to Ms. Maxwell for review and suggests a status conference to address these ongoing issues.
People (7)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable (Judge) |
The letter is addressed to The Honorable Alison J. Nathan.
|
| Ms. Maxwell | Defendant/Client |
The subject of the letter, whose ability to prepare for her defense is allegedly being impeded.
|
| Jeffrey S. Pagliuca | Defense Counsel |
The author of the letter, who signed it on behalf of the defense.
|
| MDC prison guards | Prison Guards |
Mentioned as having directed defense counsel to sit across from Ms. Maxwell, preventing simultaneous review of materi...
|
| team leader | Unspecified |
Mentioned as telling defense counsel they would not be permitted to pass papers to Ms. Maxwell.
|
| prosecutors | Prosecutor |
Mentioned as being called by defense counsel to intervene with the MDC.
|
| Counsel of Record | Attorney |
Listed in the 'CC' line, indicating they received a copy of the letter.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| BOP | Government agency |
The Bureau of Prisons, accused of exacerbating problems for the defense team.
|
| MDC | Government facility |
The Metropolitan Detention Center, where Ms. Maxwell is detained and where the legal visit took place. Its staff are ...
|
| The Government | Government agency |
Refers to the prosecution in the case, accused of creating problems by insisting on detention and not fully dischargi...
|
| The Court | Government body |
The judicial body being asked to order the BOP to allow defense counsel to pass legal papers and to schedule a status...
|
Timeline (2 events)
2020-10-23
Defense counsel visited Ms. Maxwell at the MDC to review images on a laptop. They were prevented from sitting next to her and were later told they could only pass her documents requiring a signature, not documents for review.
MDC
after 2020-11-09
The letter suggests it may be appropriate for the Court to schedule a status conference after November 9 to consider the issues raised.
Court
Locations (1)
| Location | Context |
|---|---|
|
The Metropolitan Detention Center, where Ms. Maxwell is detained and where the events described in the letter took pl...
|
Relationships (2)
Jeffrey S. Pagliuca signs the letter as defense counsel, writing on behalf of Ms. Maxwell to address issues related to her defense.
The document frames the relationship as defendant (Ms. Maxwell) versus prosecutor (The Government) in a criminal case, with disputes over discovery and conditions of confinement.
Key Quotes (3)
"It is impossible for Ms. Maxwell to participate in her defense and adequately prepare for trial if she cannot review documents prepared by her attorneys."Source
— Jeffrey S. Pagliuca
(This quote emphasizes the critical nature of the problem where defense counsel is prevented from passing review documents to Ms. Maxwell.)
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Quote #1
"The Government cannot discharge its discovery obligations by partially completing them."Source
— Jeffrey S. Pagliuca
(This quote is part of the argument that the Government must fully comply with its discovery obligations to the defense.)
DOJ-OGR-00001811.jpg
Quote #2
"The Government has created these problems by insisting on detention prior to trial. It is their burden to fix them."Source
— Jeffrey S. Pagliuca
(This quote places the responsibility for resolving the discovery access issues on the Government, linking them to their successful argument for Ms. Maxwell's pre-trial detention.)
DOJ-OGR-00001811.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,555 characters)
Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 7 of 7
The Honorable Alison J. Nathan
October 23, 2020
Page 7
October 23, 2020
Page 7
The BOP, for their part, has only exacerbated these problems. For example, on a legal visit today to review images on a laptop computer provided by the Government, we were told that we could not sit on the same side of the table as Ms. Maxwell to review the images simultaneously. Instead, we were directed by MDC prison guards to sit across from Ms. Maxwell, such that we could not see what she was reviewing or meaningfully discuss the materials.
To compound the problem, we were told by the team leader that defense counsel would not be permitted to pass Ms. Maxwell papers for her to review or sign. This required a break in the meeting so that defense counsel could call the prosecutors to intervene. The prosecutors agreed to call the MDC to ensure that defense counsel could pass legal papers to Ms. Maxwell. But that message was clearly not received by the MDC. After returning to the MDC, we were told that we could pass Ms. Maxwell only documents that required her signature, but not documents that needed her review. It is impossible for Ms. Maxwell to participate in her defense and adequately prepare for trial if she cannot review documents prepared by her attorneys. Accordingly, we ask the Court to order the BOP to allow defense counsel to pass legal papers to Ms. Maxwell for her review during prison visits.
The Government cannot discharge its discovery obligations by partially completing them. The Government must fully complete them and do so on the deadlines they agreed to with the Court. And it goes without saying that the Government cannot discharge its discovery obligations by producing the discovery to defense counsel. Ms. Maxwell has a right to review all the discovery to participate in her own defense. As such, she must have a complete set of readable discovery in the MDC, which she does not have. The Government has created these problems by insisting on detention prior to trial. It is their burden to fix them.
The Government has not requested any relief in its letter of October 7, 2020. Ms. Maxwell anticipates that once the Government responds to her discovery requests and after further conferrals the parties will be in a better position to seek relief from the Court. It may be appropriate for the Court to schedule a status conference after November 9 to consider these issues.
Respectfully Submitted,
[Signature]
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00001811
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