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740 KB

Extraction Summary

7
People
3
Organizations
1
Locations
1
Events
2
Relationships
5
Quotes

Document Information

Type: Legal filing (government letter response)
File Size: 740 KB
Summary

This is the final page (page 5) of a legal filing by the US Attorney's Office in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The Government argues that the defendant's request to use criminal discovery materials in separate civil cases should be denied because the materials are irrelevant to the civil litigation and the request attempts to bypass a protective order. The Government asserts the defendant is attempting to use these materials merely to attack the Government in a forum where it cannot respond.

People (7)

Name Role Context
Alison J. Nathan Judge
Addressee of the letter (Honorable)
Ghislaine Maxwell Defendant
Referred to as 'the defendant' (identified via Case 1:20-cr-00330)
Audrey Strauss Acting United States Attorney
Signatory of the document
Maurene Comey Assistant United States Attorney
Signatory/Author
Alison Moe Assistant United States Attorney
Signatory/Author
Lara Pomerantz Assistant United States Attorney
Signatory/Author
The Recipient Unknown Entity
Subject of alleged false accusations by the defendant regarding subpeonas

Organizations (3)

Name Type Context
United States Attorney's Office
Southern District of New York
The Government
Prosecution/Plaintiff
District Court
Southern District of New York

Timeline (1 events)

2020-08-21
Filing of Government response letter
Southern District of New York
Government Attorneys Judge Nathan

Locations (1)

Location Context
Jurisdiction of the court and attorneys

Relationships (2)

Audrey Strauss Adversarial Ghislaine Maxwell
Prosecution (US Attorney) opposing the defendant's application.
Maurene Comey Colleagues Alison Moe
Listed together as Assistant United States Attorneys.

Key Quotes (5)

"the Defense Letter completely fails to explain what legal argument she wishes to make in her Civil Cases based on the discovery materials"
Source
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Quote #1
"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
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Quote #2
"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
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Quote #3
"offer no explanation of the relevant legal theory... not to mention a compelling reason for this Court to permit an end-run around the protective order"
Source
DOJ-OGR-00001736.jpg
Quote #4
"the defendant intends to use criminal discovery materials to attack the Government in the Civil Cases"
Source
DOJ-OGR-00001736.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (2,201 characters)

Case 1:20-cr-00330-AJN Document 46 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.
DOJ-OGR-00001736

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