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753 KB

Extraction Summary

7
People
3
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 753 KB
Summary

This is page 5 of a legal letter filed on August 21, 2020, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The Government, represented by Acting US Attorney Audrey Strauss and AUSAs Comey, Moe, and Pomerantz, argues that the defendant's request to use criminal discovery materials in separate Civil Cases should be denied. The Government asserts this is an attempt to bypass protective orders and falsely accuse the Government and an unnamed 'Recipient' of malfeasance.

People (7)

Name Role Context
Alison J. Nathan Judge
Honorable Judge addressed in the letter (SDNY)
Audrey Strauss Acting United States Attorney
Signatory of the letter representing the Government
Maurene Comey Assistant United States Attorney
Signatory
Alison Moe Assistant United States Attorney
Signatory
Lara Pomerantz Assistant United States Attorney
Signatory
The Defendant Defendant
Refers to Ghislaine Maxwell (based on Case No. 1:20-cr-00330); subject of the Government's opposition
The Recipient Unknown
An individual the defendant is accused of falsely accusing of malfeasance alongside the Government

Organizations (3)

Name Type Context
United States Attorney's Office
Southern District of New York
Southern District of New York
Jurisdiction of the court
Department of Justice (DOJ)
Implied by footer 'DOJ-OGR'

Timeline (1 events)

2020-08-21
Filing of Government's opposition letter in Case 1:20-cr-00330
Southern District of New York
Government Attorneys Judge Nathan

Locations (1)

Location Context
Location of the US Attorney's Office

Relationships (2)

Audrey Strauss Colleagues Maurene Comey
Both listed as attorneys for the Government on the same filing.
The Defendant Adversarial The Recipient
Defendant accused of falsely accusing the Recipient of malfeasance.

Key Quotes (3)

"The fact that the Government issued grand jury subpoenas and obtained court authorization for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the Civil Cases."
Source
DOJ-OGR-00019553.jpg
Quote #1
"the defendant identifies no specific reason why these materials are relevant... other than to falsely accuse the Recipient and the Government of some sort of malfeasance."
Source
DOJ-OGR-00019553.jpg
Quote #2
"permit an end-run around the protective order and permit the use of criminal discovery to litigate a civil case."
Source
DOJ-OGR-00019553.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,188 characters)

Case 1:20-cr-00330-AJN Document 460 Filed 08/21/20 Page 5 of 5
Honorable Alison J. Nathan
August 21, 2020
Page 5
requested—the defendant can make such arguments, and the Government can and will vigorously oppose them, at the appropriate stage in this case.
Finally, to the extent the defendant contends that the relief requested is somehow necessary to her ability to bring issues to the attention of other courts, the Defense Letter completely fails to explain what legal argument she wishes to make in her Civil Cases based on the discovery materials she has identified or what relevance those materials have to the litigation of the Civil Cases. The fact that the Government issued grand jury subpoenas and obtained court authorization for compliance with one of those subpoenas has no conceivable relevance to disputed issues in the Civil Cases. To the extent the defendant argues that the requested relief is necessary to ensure that courts adjudicating the Civil Cases are aware of the existence of the documents at issue, the defendant identifies no specific reason why these materials are relevant to the issues pending in those cases, other than to falsely accuse the Recipient and the Government of some sort of malfeasance.⁶
In sum, the defendant’s arguments in favor of her application offer no explanation of the relevant legal theory the materials would support, not to mention a compelling reason for this Court to permit an end-run around the protective order and permit the use of criminal discovery to litigate a civil case. Accordingly, the application in the Defense Letter should be denied.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: /s
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All counsel of record, via ECF
⁶ If anything, the Defense Letter suggests that the defendant intends to use criminal discovery materials to attack the Government in the Civil Cases, attacks of no discernable relevance in those cases and made in a forum in which the Government is not a party and would have no opportunity to respond.
App.094
DOJ-OGR-00019553

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