DOJ-OGR-00001737.jpg

787 KB

Extraction Summary

3
People
3
Organizations
6
Locations
3
Events
2
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 787 KB
Summary

This is a legal letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated August 21, 2020, concerning the case against Ghislaine Maxwell. The government requests permission to file the defendant's recent letter with redactions and to file all associated exhibits under seal. The justification for this request is an ongoing grand jury investigation, with the government citing the need to protect confidential materials.

People (3)

Name Role Context
Alison J. Nathan The Honorable, Judge
Recipient of the letter, presiding judge in the case United States v. Ghislaine Maxwell.
Ghislaine Maxwell Defendant
The defendant in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).
Silvio J. Mollo
The name of the building where the United States Attorney's office is located.

Organizations (3)

Name Type Context
U.S. Department of Justice government agency
The entity sending the letter, as indicated by the letterhead.
United States Attorney Southern District of New York government agency
The specific office within the Department of Justice that is handling the case and sent the letter.
United States District Court Southern District of New York government agency
The court where the case is being heard and to which the letter is addressed.

Timeline (3 events)

2020-08-17
The defendant, Ghislaine Maxwell, filed a letter (the "Defense Letter") with the court.
United States District Court Southern District of New York
2020-08-21
The U.S. Government filed a letter with the court regarding redactions and sealing of documents in the Ghislaine Maxwell case.
United States District Court Southern District of New York
ongoing
An ongoing grand jury investigation related to the case, cited as the reason for requesting redactions and sealed filings.
U.S. Government

Locations (6)

Location Context
The location of the United States Attorney's office for the Southern District of New York.
The address of the United States Attorney's office for the Southern District of New York.
The location of the United States District Court for the Southern District of New York.
The address of the United States District Court for the Southern District of New York.
The jurisdiction of the United States Attorney and the District Court involved in the case.
The city where the U.S. Attorney's office and the Courthouse are located.

Relationships (2)

U.S. Government adversarial (legal) Ghislaine Maxwell
The document details a legal proceeding, United States v. Ghislaine Maxwell, where the Government is the prosecutor and Maxwell is the defendant.
U.S. Government professional (legal) Alison J. Nathan
The Government, as a party to the case, is formally addressing Judge Nathan, who is presiding over the proceedings.

Key Quotes (1)

"To the extent it would be useful to this Court for the Government to further elaborate on the nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental letter specifically on that subject ex parte and under seal should the Court request such an explanation."
Source
— U.S. Government (A footnote offering to provide more details about the grand jury investigation to the court privately.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,440 characters)

Case 1:20-cr-00330-AJN Document 47 Filed 08/21/20 Page 1 of 4
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
August 21, 2020
TO BE FILED PARTIALLY UNDER SEAL
BY ECF & ELECTRONIC MAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to propose certain redactions to the defendant’s letter of August 17, 2020 (the “Defense Letter”) and to request that the exhibits attached to the Defense Letter be filed under seal during the pendency of an ongoing grand jury investigation. For the reasons set forth below, the Government respectfully requests that the Court permit the filing of the Defense Letter with the proposed redactions contained in Exhibit A hereto (which itself will be submitted to the Court under seal), and that the Court permit all of the exhibits to the Defense Letter to be filed under seal. The Government does not object to the public filing of the affidavit attached to the Defense Letter in unredacted form. Additionally, the Government will file a redacted version of this letter on the public docket, and separately will submit an unreduced version to the Court.
As an initial matter, the proposed redactions, and the request that the exhibits be filed under seal, are consistent with the Government’s designation of the underlying materials as “Confidential” within the meaning of the Protective Order in this case. See Protective Order ¶ 15 (Dkt. 36). Moreover, as detailed more fully in the Government’s companion submission, that designation is appropriate given the nature of the documents at issue, all of which pertain to the Government’s pending grand jury investigation.¹ That alone strongly weighs in favor of permitting the redactions and sealed filings at issue: Federal Rule of Criminal Procedure 6(e)(6) provides, in relevant part,
¹ To the extent it would be useful to this Court for the Government to further elaborate on the nature of the ongoing grand jury investigation, the Government is prepared to file a supplemental letter specifically on that subject ex parte and under seal should the Court request such an explanation.
DOJ-OGR-00001737

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