EFTA00027704.pdf
72.3 KB
Extraction Summary
4
People
4
Organizations
2
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / letter motion
File Size:
72.3 KB
Summary
A letter from U.S. Attorney Damian Williams to Judge Alison J. Nathan dated October 18, 2021, regarding the case United States v. Ghislaine Maxwell. The Government requests permission to file motions *in limine* with redactions designed to protect the privacy of victims and third parties, specifically requesting the sealing of 'Section X' until the conclusion of the trial. The specific Assistant US Attorney signing the document has their name redacted.
People (4)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
The Honorable District Court Judge addressed in the letter.
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell).
|
| Damian Williams | United States Attorney |
Signatory for the prosecution.
|
| [REDACTED] | Assistant United States Attorney |
Signatory whose name is redacted on page 2.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | ||
| United States Attorney Southern District of New York | ||
| United States District Court Southern District of New York | ||
| Second Circuit |
Cited for legal precedent (Lugosch v. Pyramid Co. of Onondaga).
|
Timeline (1 events)
2021-10-18
Submission of Government's motions in limine under seal with proposed redactions.
Southern District of New York
US Government
Judge Alison J. Nathan
Locations (2)
| Location | Context |
|---|---|
|
Office of the US Attorney.
|
|
|
Address of the District Court.
|
Relationships (1)
Prosecutor in US v. Maxwell case.
Key Quotes (4)
"The Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions."Source
EFTA00027704.pdf
Quote #1
"the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case"Source
EFTA00027704.pdf
Quote #2
"the Government seeks redaction of Section X at least until the conclusion of trial."Source
EFTA00027704.pdf
Quote #3
"Additional justification for this sealing request is located in footnote 11 on page 49 of the Government’s motions in limine."Source
EFTA00027704.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (1,780 characters)
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
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 18, 2021
BY ECF
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
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 its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government’s proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government’s motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document.
In addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government’s motions in limine.
EFTA00027704
Page 2
Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
By: s/ [REDACTED]
Assistant United States Attorneys
Southern District of New York
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
EFTA00027705
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