DOJ-OGR-00005389.jpg
461 KB
Extraction Summary
4
People
3
Organizations
2
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
461 KB
Summary
This document is a letter dated October 27, 2021, from defense attorney Jeffrey Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter informs the court that the defense is filing a motion under Federal Rule of Evidence 412 (regarding sexual behavior evidence) under seal. It also outlines the defense's plan to serve redacted copies of this motion to the counsel of the specific alleged victims whose behavior is discussed in the motion.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Defense Attorney |
Attorney for Ghislaine Maxwell; Sender of the letter
|
| Alison J. Nathan | Judge |
Recipient of the letter; Presiding Judge for United States District Court, Southern District of New York
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell); filing a motion under Federal Rule of Evidence 412
|
| Alleged Victims | Victims |
Referenced regarding notification requirements under Rule 412; their behavior is noted as being 'at issue' in the motion
|
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 |
Court receiving the filing
|
|
| DOJ |
Department of Justice (indicated by footer DOJ-OGR numbering)
|
Timeline (1 events)
October 27, 2021
Filing of Ms. Maxwell's motion under Federal Rule of Evidence 412 (sealed).
Southern District of New York
Locations (2)
| Location | Context |
|---|---|
|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of United States District Court
|
Relationships (2)
Pagliuca submits the letter on behalf of Ms. Maxwell.
Letter addressed to Judge Nathan regarding US v. Maxwell.
Key Quotes (4)
"Attached is Ms. Maxwell’s motion under Federal Rule of Evidence 412."Source
DOJ-OGR-00005389.jpg
Quote #1
"Subsection (2)(c) of the Rule requires this motion to be sealed unless this Court orders otherwise."Source
DOJ-OGR-00005389.jpg
Quote #2
"The Rule also requires Ms. Maxwell to notify the alleged victims whose behavior is at issue in the motion."Source
DOJ-OGR-00005389.jpg
Quote #3
"we will serve a redacted copy of this motion tailored to each alleged victim addressed in the motion on their counsel of record"Source
DOJ-OGR-00005389.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,207 characters)
Case 1:20-cr-00330-PAE Document 377 Filed 10/27/21 Page 1 of 1
HADDON
MORGAN
FOREMAN
MORGAN
FOREMAN
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
Jeffrey 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
October 27, 2021
VIA ECF
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:
Attached is Ms. Maxwell’s motion under Federal Rule of Evidence 412. Subsection (2)(c) of the Rule requires this motion to be sealed unless this Court orders otherwise. Accordingly, unless instructed by the Court, Ms. Maxwell will not file this motion on the public docket.
The Rule also requires Ms. Maxwell to notify the alleged victims whose behavior is at issue in the motion. Accordingly, unless otherwise directed, we will serve a redacted copy of this motion tailored to each alleged victim addressed in the motion on their counsel of record and provide proof of service to the Court when it is accomplished.
Respectfully Submitted,
[Signature]
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00005389
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