DOJ-OGR-00005262.jpg
623 KB
Extraction Summary
6
People
4
Organizations
3
Locations
4
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / court document (letter motion)
File Size:
623 KB
Summary
This document is page 3 of a legal filing dated October 18, 2021, addressed to Judge Alison J. Nathan regarding the case of Ghislaine Maxwell. The defense argues they have received voluminous discovery materials (over 14,000 pages) from the government very recently (Oct 11-12), leaving insufficient time to review them before filing motions in limine. The document details the logistics of the hard drive deliveries to counsel in New York and Colorado, and to Ms. Maxwell at the MDC, while noting that some materials provided to Maxwell were incomplete.
People (6)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Addressee of the letter ('The Honorable')
|
| Ghislaine Maxwell | Defendant |
Referred to as 'Ms. Maxwell'; received hard drive late; held at MDC
|
| Mr. Pagliuca | Defense Counsel |
Quoted in footnote regarding motion schedules during arraignment
|
| Ms. Comey | Prosecutor / Government Counsel |
Quoted in footnote regarding supplemental motions
|
| New York counsel | Defense Team |
Picked up hard drives from U.S. Attorney's Office
|
| Colorado counsel | Defense Team |
Received hard drives via Federal Express
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Attorney’s Office |
Source of the discovery hard drives
|
|
| Federal Express |
Courier service used to deliver hard drives to Colorado counsel
|
|
| MDC |
Metropolitan Detention Center; location where Maxwell is held and legal mail was deposited
|
|
| DOJ |
Department of Justice (referenced in footer DOJ-OGR-00005262)
|
Timeline (4 events)
2021-04-23
Arraignment where scheduling issues were discussed (referenced in footnote).
Court
2021-10-11
Government produced Jencks Act and Giglio material and exhibit list.
New York
Government
Defense Counsel
2021-10-14
Ms. Maxwell received her hard drive (missing some .pdf disclosures).
MDC
Ms. Maxwell
Relationships (2)
Pagliuca arguing on behalf of the defense schedule in the context of Maxwell's case.
Comey representing the government's position in court transcripts.
Key Quotes (3)
"approximately 6,000 pages on “non-testifying” witness materials, the bulk of which is exculpatory"Source
DOJ-OGR-00005262.jpg
Quote #1
"Counsel have been unable to thoroughly review and analyze this voluminous production in sufficient time"Source
DOJ-OGR-00005262.jpg
Quote #2
"[W]e don’t think it’s tenable to stick to the motion in limine schedule based on the government’s proposed disclosures."Source
DOJ-OGR-00005262.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,874 characters)
Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 3 of 4
The Honorable Alison J. Nathan
October 18, 2021
Page 3
whether additional motions are required based on voluminous disclosures made less than one
week ago.¹
The Honorable Alison J. Nathan
October 18, 2021
Page 3
whether additional motions are required based on voluminous disclosures made less than one
week ago.¹
By court order, the government produced Jencks Act and Giglio material and a list of
government exhibits on the evening of October 11. New York counsel picked up the hard drives
from the U.S. Attorney’s Office that evening. Colorado counsel received their hard drives via
Federal Express on October 12 at approximately 6:30 p.m. The hard drives contained thousands
of pages of disclosures: approximately 8,000 single-space typed and hand-written pages of
testifying witness materials; approximately 6,000 pages on “non-testifying” witness materials,
the bulk of which is exculpatory; and Excel spreadsheets identifying hundreds of government
exhibits.
government exhibits on the evening of October 11. New York counsel picked up the hard drives
from the U.S. Attorney’s Office that evening. Colorado counsel received their hard drives via
Federal Express on October 12 at approximately 6:30 p.m. The hard drives contained thousands
of pages of disclosures: approximately 8,000 single-space typed and hand-written pages of
testifying witness materials; approximately 6,000 pages on “non-testifying” witness materials,
the bulk of which is exculpatory; and Excel spreadsheets identifying hundreds of government
exhibits.
Ms. Maxwell received her hard drive late morning on October 14 without inclusion of
various .pdf disclosures, most significantly the government’s exhibit list, which counsel copied,
hand-delivered, and deposited in the MDC legal mailbox on October 17.
various .pdf disclosures, most significantly the government’s exhibit list, which counsel copied,
hand-delivered, and deposited in the MDC legal mailbox on October 17.
Counsel have been unable to thoroughly review and analyze this voluminous production
in sufficient time to assess whether additional motions in limine are required. Nor has Ms.
in sufficient time to assess whether additional motions in limine are required. Nor has Ms.
¹ This issue was discussed during the arraignment on April 23, 2021:
MR. PAGLIUCA: [W]e don’t think it’s tenable to stick to the motion in limine
schedule based on the government’s proposed disclosures.
schedule based on the government’s proposed disclosures.
Dkt. 261 at 6.
MS. COMEY: And as is typical with trials in this district, it is possible there may
be supplemental motions in limine after the date that the parties have proposed
for motions in limine in this case.
be supplemental motions in limine after the date that the parties have proposed
for motions in limine in this case.
Id.
THE COURT: And to the extent that there is some additional supplementation
after that date, we can consider that.
after that date, we can consider that.
Id. at 8.
DOJ-OGR-00005262
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