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701 KB
Extraction Summary
5
People
3
Organizations
4
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
701 KB
Summary
This is a letter dated July 27, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan of the Southern District of New York. The attorneys request the court to enter a protective order for discovery materials in the case of United States v. Ghislaine Maxwell. The letter highlights that while most terms have been agreed upon with the government, two key disputes remain: whether government witnesses should face the same restrictions as the defense regarding discovery materials, and whether the defense should be allowed to identify alleged victims or witnesses who are already public.
People (5)
| Name | Role | Context |
|---|---|---|
| Mark S. Cohen | Attorney |
Listed as an attorney from Cohen & Gresser LLP, the firm representing Ghislaine Maxwell.
|
| Christian R. Everdell | Attorney |
Listed as an attorney from Cohen & Gresser LLP, the firm representing Ghislaine Maxwell.
|
| Alison J. Nathan | Judge |
The Honorable Alison J. Nathan, the judge at the United States District Court to whom the letter is addressed.
|
| Ghislaine Maxwell | Client/Defendant |
The client of Cohen & Gresser LLP and the defendant in the case United States v. Ghislaine Maxwell.
|
| Ms. Maxwell | Client/Defendant |
A reference to Ghislaine Maxwell, mentioned in the context of receiving discovery material.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| COHEN & GRESSER LLP | company |
The law firm representing Ghislaine Maxwell and the author of this letter.
|
| United States District Court | government agency |
The court where the case is being heard, specifically the Southern District of New York.
|
| The government | government agency |
The prosecution in the case United States v. Ghislaine Maxwell.
|
Timeline (2 events)
2020-07-09
The government provided defense counsel with an initial draft of a proposed protective order.
The government
defense counsel
2020-07-27
The letter from Cohen & Gresser LLP to Judge Nathan was filed with the court.
United States District Court, Southern District of New York
Locations (4)
| Location | Context |
|---|---|
|
The address of the law firm Cohen & Gresser LLP.
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|
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The jurisdiction of the United States District Court where the case is filed.
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The address of the United States District Court where Judge Nathan presides.
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|
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The city where the law firm and the courthouse are located.
|
Relationships (3)
The letter states, 'On behalf of our client, Ghislaine Maxwell...'. Mark S. Cohen is listed as an attorney from the firm sending the letter.
The letter states, 'On behalf of our client, Ghislaine Maxwell...'. Christian R. Everdell is listed as an attorney from the firm sending the letter.
The document details a legal case, United States v. Ghislaine Maxwell, where Cohen & Gresser LLP represents the defense and is in negotiation and dispute with 'the government' (the prosecution).
Key Quotes (3)
"On behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A."Source
— Cohen & Gresser LLP
(The opening statement of the letter, stating its primary purpose.)
DOJ-OGR-00001643.jpg
Quote #1
"First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet."Source
— Cohen & Gresser LLP
(Describing the first of two key disputes with the government over the protective order.)
DOJ-OGR-00001643.jpg
Quote #2
"Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record."Source
— Cohen & Gresser LLP
(Describing the second key dispute with the government over the protective order.)
DOJ-OGR-00001643.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,126 characters)
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 1 of 4
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Mark S. Cohen
+1 (212) 957-7600
mcohen@cohengresser.com
+1 (212) 957-7600
mcohen@cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
+1 (212) 957-7600
ceverdell@cohengresser.com
July 27, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A.
The government has indicated that it requires the entry of a protective order before producing any discovery material to Ms. Maxwell. On July 9, 2020, the government provided defense counsel with an initial draft of a proposed protective order. Since that time, the parties have conferred several times on conference calls and by email, and have been able to reach agreement on almost all of the provisions of the proposed protective order.
Two key disputes remain, however, which require the Court’s guidance. First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet. Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record.
As set forth below, we believe that the proposed protective order contains appropriate restrictions that are no broader than necessary to protect the privacy interests of individuals
DOJ-OGR-00001643
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