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812 KB

Extraction Summary

2
People
5
Organizations
6
Locations
3
Events
2
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 812 KB
Summary

This is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Dated January 28, 2021, the letter responds to a court order about proposed redactions to the defendant's pre-trial motions. The Government states its agreement with the proposed redactions, arguing they are necessary to protect the integrity of an ongoing investigation, maintain grand jury secrecy, and protect the privacy of victim-witnesses.

People (2)

Name Role Context
Alison J. Nathan Judge, United States District Court
Recipient of the letter, addressed as "The Honorable Alison J. Nathan" and "Dear Judge Nathan".
Ghislaine Maxwell Defendant
The defendant in the case "United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)".

Organizations (5)

Name Type Context
U.S. Department of Justice Government agency
The entity sending the letter.
United States Attorney Southern District of New York Government agency
The specific office within the Department of Justice that authored the letter.
United States District Court Southern District of New York Court
The court where Judge Alison J. Nathan presides and where the case is being heard.
Douglas Oil Co. Company
Mentioned in a legal citation: "Douglas Oil Co. v. Petrol Stops Northwest".
Petrol Stops Northwest Company
Mentioned in a legal citation: "Douglas Oil Co. v. Petrol Stops Northwest".

Timeline (3 events)

2021-01-25
The defendant, Ghislaine Maxwell, filed her pre-trial motions.
United States District Court Southern District of New York
2021-01-26
The Court issued an order providing the Government an opportunity to respond to the defendant's proposed redactions.
United States District Court Southern District of New York
Alison J. Nathan U.S. Government
2021-01-28
The Government submitted this letter in response to the Court's order.
United States District Court Southern District of New York
U.S. Government

Locations (6)

Location Context
The building where the United States Attorney's office is located.
The address of the United States Attorney's office.
The location of the United States District Court.
The address of the United States Courthouse.
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 the legal proceedings of "United States v. Ghislaine Maxwell," where the U.S. Government is the prosecution and Ghislaine Maxwell is the defendant.
U.S. Government Professional (legal) Alison J. Nathan
The U.S. Government, as a party in a case, is formally addressing Judge Alison J. Nathan, who is presiding over the case, in response to a court order.

Key Quotes (1)

"Since the 17th century, grand jury proceedings have been closed to the public; and records of such proceedings have been kept from the public eye. The rule of grand jury secrecy . . . is an integral part of our criminal justice system."
Source
— Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) (Quoted as legal precedent to justify redactions related to grand jury secrecy and to protect the integrity of an ongoing investigation.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,367 characters)

Case 1:20-cr-00330-AJN Document 128 Filed 01/28/21 Page 1 of 2
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
January 28, 2021
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 in response to the Court’s order dated January 26, 2021 providing the Government with an opportunity to respond to the defendant’s proposed redactions to its pre-trial motions filed on January 25, 2021. The Government notes at the outset that the defendant has not proposed any redactions to certain motions filed on the docket. (Motions 5, 8, 9, & 12; Dkts. 119-126). The Government agrees that no redactions are necessary as to those particular motions. The Government agrees with the defendant’s proposed redactions to the remaining pre-trial motions for the following reasons:
- The proposed redactions to the defendant’s motion to dismiss for breach of the non-prosecution agreement (Motion 1) and the motion to dismiss for pre-indictment delay (Motion 7) refer to documents designated by the Government as “Confidential” within the meaning of the Protective Order in this case (see Protective Order ¶ 15 (Dkt. 36)), and the proposed redactions are narrowly tailored to protect the integrity of the Government’s ongoing investigation. See, e.g., Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 218 n.9 (1979) (“Since the 17th century, grand jury proceedings have been closed to the public; and records of such proceedings have been kept from the public eye. The rule of grand jury secrecy . . . is an integral part of our criminal justice system.”).
- The proposed redactions to the defendant’s motion to dismiss Counts One through Four of the Superseding Indictment as time-barred (Motion 2) and her motion to strike surplusage from the Superseding Indictment (Motion 6) protect the privacy interests of victim-witnesses.
- The proposed redactions to the motion to dismiss Counts Five and Six (Motion 4) refer to documents designated by the Government as “Confidential” within the
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