DOJ-OGR-00008431.jpg
469 KB
Extraction Summary
5
People
3
Organizations
5
Locations
1
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
469 KB
Summary
This legal document is a letter dated December 15, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter is a response to the government's motion to prevent a witness, Alexander Hamilton, from testifying about four specific topics related to an individual named 'Kate'. The defense argues that providing Hamilton's declaration to the government under Rule 26.2 does not obligate them to introduce all of its contents as evidence.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Attorney |
Author of the letter, from the law firm Haddon, Morgan and Foreman, P.C.
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| Alison J. Nathan | The Honorable, Judge |
Recipient of the letter, presiding judge for the United States District Court, Southern District of New York.
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| Ghislaine Maxwell | Defendant |
Defendant in the case United States v. Ghislaine Maxwell, referred to as Ms. Maxwell.
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| Alexander Hamilton | Potential Witness |
Individual whose testimony the government seeks to preclude, referred to as Mr. Hamilton.
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| Kate |
Individual who is the subject of Alexander Hamilton's potential testimony.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C | law firm |
Law firm listed on the letterhead, employing Jeffrey S. Pagliuca.
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| United States District Court, Southern District of New York | government agency |
The court where Judge Alison J. Nathan presides and where the case is being heard.
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| United States Government | government agency |
The prosecuting party in the case, referred to as 'the government'.
|
Timeline (1 events)
2021-12-15
Defense attorney Jeffrey S. Pagliuca submitted a letter in response to the government's motion to preclude testimony from Alexander Hamilton in the case of U.S. v. Ghislaine Maxwell.
United States District Court, Southern District of New York
Locations (5)
| Location | Context |
|---|---|
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Address of the law firm Haddon, Morgan and Foreman, P.C.
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Location of the law firm Haddon, Morgan and Foreman, P.C.
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Address of the United States District Court, Southern District of New York.
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Location of the United States District Court.
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The jurisdiction of the court hearing the case.
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Relationships (3)
Jeffrey S. Pagliuca is an attorney from Haddon, Morgan and Foreman, P.C. writing on behalf of Ms. Maxwell in her criminal case.
The document discusses testimony about Kate's statements made to Mr. Hamilton, indicating they have communicated.
The document is a filing in the criminal case 'United States v. Ghislaine Maxwell', where the government is the prosecutor and Maxwell is the defendant.
Full Extracted Text
Complete text extracted from the document (1,200 characters)
Case 1:20-cr-00330-PAE Document 555 Filed 12/18/21 Page 1 of 5
HADDON, MORGAN AND FOREMAN, P.C
Jeffrey S. Pagliuca
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
December 15, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write in response to the government’s motion to preclude certain testimony by Alexander Hamilton. Based on a defense Rule 26.2 disclosure, the government’s motion identifies four categories of testimony it asks this Court to preclude:
(1) Testimony about Kate’s [REDACTED].
(2) Testimony describing Kate as [REDACTED].
(3) Testimony about Kate’s statements to Mr. Hamilton.
(4) Testimony about Mr. Hamilton’s [REDACTED] of Kate’s account of her alleged abuse.
Gov. Letter, pp 8-10.
Ms. Maxwell provided Mr. Hamilton’s declaration to the government under Rule 26.2 because that is what the Rule requires. But just as the government does not intend to admit evidence about every disclosure it makes, so too here.
DOJ-OGR-00008431
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