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837 KB
Extraction Summary
2
People
3
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / government opposition letter
File Size:
837 KB
Summary
This document is a letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan dated August 21, 2020, regarding United States v. Ghislaine Maxwell. The Government opposes the defendant's request to use confidential discovery materials from this criminal case in unrelated civil litigation. The letter notes that over 165,000 pages of discovery have been produced and argues that the materials in question relate to an ongoing criminal investigation and grand jury proceedings.
People (2)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Recipient of the letter; United States District Court Judge.
|
| Ghislaine Maxwell | Defendant |
Defendant in case 20 Cr. 330 (AJN); requesting permission to file discovery materials in civil cases.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Header of the document.
|
|
| United States Attorney Southern District of New York |
Author of the letter.
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|
| United States District Court Southern District of New York |
The court handling the case.
|
Locations (2)
| Location | Context |
|---|---|
|
Office of the U.S. Attorney.
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|
|
Address for Judge Alison J. Nathan.
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Relationships (2)
Case title: United States v. Ghislaine Maxwell
Judge presiding over defendant's case
Key Quotes (5)
"The Government respectfully submits this letter in opposition to the defendant’s letter of August 17, 2020"Source
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Quote #1
"Indeed, the Government has already produced more than 165,000 pages of discovery to the defense"Source
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Quote #2
"the defendant seeks permission to use, in unrelated civil litigation, materials produced pursuant to the protective order in this case and designated 'Confidential'"Source
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Quote #3
"pertain to an ongoing criminal investigation"Source
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Quote #4
"materials that are sealed and that would jeopardize an ongoing grand jury investigation if filed publicly"Source
DOJ-OGR-00001732.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,529 characters)
Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 1 of 5
U.S. Department of Justice
United States Attorney
Southern District of New York
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
One Saint Andrew's Plaza
New York, New York 10007
August 21, 2020
VIA 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 this letter in opposition to the defendant’s letter of
August 17, 2020 (the “Defense Letter”), requesting that the Court enter an order permitting the
defendant to file under seal in certain civil cases (the “Civil Cases”) discovery materials produced
by the Government in the instant criminal case, and to refer to, but not file, additional other
discovery materials produced by the Government in the Civil Cases. Those applications should
be denied.¹
August 17, 2020 (the “Defense Letter”), requesting that the Court enter an order permitting the
defendant to file under seal in certain civil cases (the “Civil Cases”) discovery materials produced
by the Government in the instant criminal case, and to refer to, but not file, additional other
discovery materials produced by the Government in the Civil Cases. Those applications should
be denied.¹
As an initial matter, the Government has already produced, and will continue to produce,
substantial volumes of materials in discovery consistent with its obligations. Those include
materials the Government obtained via search warrant, grand jury subpoenas, or other investigative
methods available only to the Government. Indeed, the Government has already produced more
than 165,000 pages of discovery to the defense, including the materials relevant to the Defense
Letter. Through her most recent application, the defendant seeks permission to use, in unrelated
civil litigation, materials produced pursuant to the protective order in this case and designated
“Confidential” thereunder. As detailed herein, the Government’s designation is entirely
appropriate given that the materials—court orders and applications—have been kept under seal by
the issuing judges, and pertain to an ongoing criminal investigation.
substantial volumes of materials in discovery consistent with its obligations. Those include
materials the Government obtained via search warrant, grand jury subpoenas, or other investigative
methods available only to the Government. Indeed, the Government has already produced more
than 165,000 pages of discovery to the defense, including the materials relevant to the Defense
Letter. Through her most recent application, the defendant seeks permission to use, in unrelated
civil litigation, materials produced pursuant to the protective order in this case and designated
“Confidential” thereunder. As detailed herein, the Government’s designation is entirely
appropriate given that the materials—court orders and applications—have been kept under seal by
the issuing judges, and pertain to an ongoing criminal investigation.
________________________
¹ The Government has drafted this letter in a manner that avoids revealing the contents of sealed
materials and grand jury information. Accordingly, the Government does not seek permission to
seal or redact this submission. Because the Defense Letter repeatedly references, and attaches as
exhibits, materials that are sealed and that would jeopardize an ongoing grand jury investigation if
filed publicly, the Government intends to submit a separate letter, under seal, proposing redactions
to the Defense Letter and requesting that the attachments to the Defense Letter be filed under seal.
¹ The Government has drafted this letter in a manner that avoids revealing the contents of sealed
materials and grand jury information. Accordingly, the Government does not seek permission to
seal or redact this submission. Because the Defense Letter repeatedly references, and attaches as
exhibits, materials that are sealed and that would jeopardize an ongoing grand jury investigation if
filed publicly, the Government intends to submit a separate letter, under seal, proposing redactions
to the Defense Letter and requesting that the attachments to the Defense Letter be filed under seal.
DOJ-OGR-00001732
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