DOJ-OGR-00001752.jpg
496 KB
Extraction Summary
3
People
3
Organizations
5
Locations
4
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
496 KB
Summary
This document is a letter motion dated August 17, 2020, from attorney Jeffrey Pagliuca on behalf of his client, defendant Ghislaine Maxwell, to Judge Alison J. Nathan of the U.S. District Court for the Southern District of New York. The motion requests a modification of the existing protective order to allow Maxwell's defense to refer to and file under seal certain discovery materials provided by the government on August 5 and August 13, 2020. The defense argues this is necessary for the fair determination of issues in what is referred to as the "Other Matters".
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The recipient of the letter, addressed as "The Honorable Alison J. Nathan" and "Dear Judge Nathan".
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| Ghislaine Maxwell | Defendant |
The defendant in the case "United States v. Ghislaine Maxwell", on whose behalf the letter is written.
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| Jeffrey Pagliuca | Attorney |
Listed as the contact person for the law firm Haddon, Morgan and Foreman, P.C, and likely the author of the letter.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C | company |
The law firm representing the defendant, Ghislaine Maxwell. The letter is on their letterhead.
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| 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. Also referred to as USDC SDNY.
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| United States | government agency |
The prosecuting party in the case "United States v. Ghislaine Maxwell".
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Timeline (4 events)
2020-08-17
2020-09-02
Date the document was electronically filed with the court.
Southern District of New York
Locations (5)
| Location | Context |
|---|---|
|
Location of the law firm Haddon, Morgan and Foreman, P.C.
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Address of the law firm Haddon, Morgan and Foreman, P.C.
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The district of the United States District Court handling the case.
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Location of the United States District Court.
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Address of the United States District Court.
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Relationships (2)
Jeffrey Pagliuca's law firm, Haddon, Morgan and Foreman, P.C, is representing Defendant Ghislaine Maxwell in her criminal case.
Ghislaine Maxwell is the defendant in a case being presided over by Judge Alison J. Nathan.
Full Extracted Text
Complete text extracted from the document (1,373 characters)
Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 1 of 8
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/2/20
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/2/20
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.hmlaw.com
jpagliuca@hmlaw.com
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmlaw.com
jpagliuca@hmlaw.com
August 17, 2020
VIA EMAIL
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: Request to Modify Protective Order (UNDER SEAL)¹
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court’s Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in [REDACTED] (the “Other Matters”), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically [REDACTED].²
Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues [REDACTED]
¹ Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case.
² [REDACTED]
DOJ-OGR-00001752
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