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559 KB
Extraction Summary
4
People
3
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (reply brief/letter motion)
File Size:
559 KB
Summary
This document is a legal reply from Ghislaine Maxwell's attorney, Jeffrey Pagliuca, to Judge Alison J. Nathan, dated August 24, 2020. It supports a request to modify a protective order to allow Maxwell to disclose to an adversary in a separate civil litigation that said adversary has already provided materials to the U.S. Attorney's Office via subpoena. The document argues against the government's stance that the civil litigation is unrelated and that disclosure would jeopardize the criminal investigation.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case and the party requesting modification of a protective order.
|
| Alison J. Nathan | Judge |
Recipient of the letter; United States District Court Judge.
|
| Jeffrey Pagliuca | Attorney |
Sender of the letter; Attorney at Haddon, Morgan and Foreman, representing Maxwell.
|
| [Redacted] | Adversary |
An adversary in a related Civil Litigation who handed materials to the U.S. Attorney's Office.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
The court handling the case.
|
|
| U.S. Attorney's Office |
Prosecution; recipient of subpoenaed materials.
|
Timeline (3 events)
August 17, 2020
Proposed redactions to Request to Modify Protective Order filed by Ms. Maxwell.
New York, NY (SDNY)
August 18, 2020
Court Order (Doc. 44) referenced regarding filing procedures.
New York, NY (SDNY)
Judge Alison J. Nathan
August 24, 2020
Filing of Reply in Support of Request to Modify Protective Order.
New York, NY (SDNY)
Locations (2)
| Location | Context |
|---|---|
|
Address of the United States District Court.
|
|
|
Address of Haddon, Morgan and Foreman, P.C.
|
Relationships (2)
Pagliuca is sending the letter on behalf of Defendant Maxwell from his law firm.
Text refers to 'her adversary [REDACTED]' in the 'Civil Litigation'.
Key Quotes (4)
"Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to [REDACTED] (the 'Civil Litigation') the fact that her adversary [REDACTED] already handed over [REDACTED], to the U.S. Attorney’s Office pursuant to a subpoena"Source
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Quote #1
"The government proposes to keep [REDACTED] in the dark about the fact and method of the disclosure."Source
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Quote #2
"They claim the civil litigation is 'unrelated,' that issuance of the subpoena was 'standard practice,' and that disclosure will jeopardize an ongoing criminal investigation"Source
DOJ-OGR-00019574.jpg
Quote #3
"First, the government claims the civil litigation is [REDACTED] Resp. at 1. The assertion is frivolous."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,922 characters)
Case 1:20-cr-00330-AJN Document 342 Filed 09/08/20 Page 1 of 6
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
Jeffrey Pagliuca
[Logo]
H A D D O N
M O R G A N
F O R E M A N
H A D D O N
M O R G A N
F O R E M A N
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
August 24, 2020
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: Reply in Support of Request to Modify Protective Order (Under Seal)¹
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to [REDACTED] (the “Civil Litigation”) the fact that her adversary [REDACTED] already handed over [REDACTED], to the U.S. Attorney’s Office pursuant to a subpoena [REDACTED]
The government proposes to keep [REDACTED] in the dark about the fact and method of the disclosure. They claim the civil litigation is “unrelated,” that issuance of the subpoena was “standard practice,” and that disclosure will jeopardize an ongoing criminal investigation and “permit dissemination of a vast swath of materials.” Each of the government’s arguments lack merit.
The Civil Litigation [REDACTED]:
First, the government claims the civil litigation is [REDACTED] Resp. at 1. The assertion is frivolous. [REDACTED]
First, the government claims the civil litigation is [REDACTED] Resp. at 1. The assertion is frivolous. [REDACTED]
________________________
¹ Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court’s Order of August 18, 2020 (Doc. 44).
¹ Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court’s Order of August 18, 2020 (Doc. 44).
App.115
DOJ-OGR-00019574
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