DOJ-OGR-00008804.jpg
558 KB
Extraction Summary
5
People
5
Organizations
5
Locations
3
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
558 KB
Summary
This document is a letter dated January 5, 2022, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Pagliuca argues against the government's request for a hearing concerning a juror who revealed post-trial that they were a victim of sexual assault. He contends the request is premature and that, based on publicly available information and legal precedent, the court should order a new trial without an evidentiary hearing.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Attorney |
Sender of the letter, from the law firm Haddon, Morgan and Foreman, P.C.
|
| Alison J. Nathan | The Honorable, Judge |
Recipient of the letter, judge for the United States District Court, Southern District of New York.
|
| Ghislaine Maxwell | Defendant |
Defendant in the case United States v. Ghislaine Maxwell.
|
| Greenwood | Party in a lawsuit |
Mentioned in the case citation McDonough Power Equip., Inc. v. Greenwood.
|
| Langford | Party in a lawsuit |
Mentioned in the case citation United States v. Langford.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C | law firm |
The law firm of the letter's author, Jeffrey S. Pagliuca.
|
| United States District Court, Southern District of New York | government agency |
The court where Judge Alison J. Nathan presides and where the case is being heard.
|
| The Supreme Court | government agency |
Cited for having established a legal standard for granting a new trial based on juror conduct.
|
| McDonough Power Equip., Inc. | company |
A party in the cited legal case McDonough Power Equip., Inc. v. Greenwood.
|
| DOJ | government agency |
Appears in the footer identifier 'DOJ-OGR-00008804', likely standing for Department of Justice.
|
Timeline (3 events)
2022-01-05
Filing of a letter by Jeffrey S. Pagliuca to Judge Nathan in the case of United States v. Ghislaine Maxwell.
United States District Court, Southern District of New York
2022-01-05
The government submitted a letter requesting a hearing to consider a juror's statements.
United States District Court, Southern District of New York
the government
The ongoing legal case of United States v. Ghislaine Maxwell.
United States District Court, Southern District of New York
United States
Ghislaine Maxwell
Locations (5)
| Location | Context |
|---|---|
|
Address of the law firm Haddon, Morgan and Foreman, P.C.
|
|
|
Location of the law firm Haddon, Morgan and Foreman, P.C.
|
|
|
The jurisdiction of the United States District Court mentioned in the letter.
|
|
|
Address of the United States District Court.
|
|
|
Location of the United States District Court.
|
Relationships (3)
Jeffrey S. Pagliuca is writing to the judge on behalf of Ghislaine Maxwell in her criminal case, indicating he is her legal counsel.
Pagliuca, an attorney, is addressing Judge Nathan, the presiding judge in a case he is involved in.
The document is from the case titled 'United States v. Ghislaine Maxwell', indicating they are opposing parties in a criminal prosecution.
Key Quotes (2)
"a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause."Source
— The Supreme Court
(Cited from the case McDonough Power Equip., Inc. v. Greenwood to establish the standard for being entitled to a new trial due to juror misconduct.)
DOJ-OGR-00008804.jpg
Quote #1
"We read [the McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate."Source
— 2d Circuit Court
(Cited from the case United States v. Langford to show that the standard applies even if the juror's conduct was not intentional.)
DOJ-OGR-00008804.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,542 characters)
Case 1:20-cr-00330-PAE Document 570 Filed 01/05/22 Page 1 of 3
HADDON
MORGAN
FOREMAN
MORGAN
FOREMAN
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
Jeffrey S. 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
January 5, 2022
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,
I write in response to the government’s letter of this morning requesting a hearing to consider a Juror’s statements to various media sources that the Juror was a victim of sexual assault. Doc. 568. The government’s request for a hearing is premature because based on undisputed, publicly available information, the Court can and should order a new trial without any evidentiary hearing.
The Supreme Court has held that to be entitled to a new trial, “a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause. McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). This standard applies even if the juror’s conduct was merely inadvertent and not intentional. United States v. Langford, 990 F.2d 65, 68 (2d Cir. 1993) (“We read [the McDonough] multi-part test as governing not only inadvertent nondisclosures but also nondisclosures or misstatements that were deliberate.”).
DOJ-OGR-00008804
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document