DOJ-OGR-00019498.jpg
714 KB
Extraction Summary
5
People
3
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / letter motion
File Size:
714 KB
Summary
This document is a letter dated July 27, 2020, from Ghislaine Maxwell's defense attorneys (Cohen & Gresser LLP) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense is requesting the entry of a protective order regarding discovery materials but outlines two remaining disputes with the government: 1) restrictions on government witnesses posting discovery materials to the internet, and 2) the defense's ability to publicly identify alleged victims who have already spoken on the public record.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Client |
Client represented by Cohen & Gresser, subject of the criminal case.
|
| Alison J. Nathan | Judge |
Recipient of the letter, Judge for United States District Court, SDNY.
|
| Mark S. Cohen | Attorney |
Sender, partner at Cohen & Gresser LLP representing Maxwell.
|
| Christian R. Everdell | Attorney |
Sender, partner at Cohen & Gresser LLP representing Maxwell.
|
| Alleged Victims/Potential Witnesses | Subjects of Discovery |
Individuals whose identities are a subject of dispute regarding public disclosure in the protective order.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court Southern District of New York |
Court jurisdiction.
|
|
| The Government |
Prosecution/Department of Justice.
|
Timeline (1 events)
2020-07-27
Filing of Document 29 in Case 1:20-cr-00330-AJN
New York, NY
Cohen & Gresser LLP
US District Court SDNY
Locations (2)
| Location | Context |
|---|---|
|
Address of the recipient (Judge Nathan).
|
|
|
Address of the sender.
|
Relationships (2)
Letter states 'On behalf of our client, Ghislaine Maxwell...'
Letter states 'On behalf of our client, Ghislaine Maxwell...'
Key Quotes (3)
"Two key disputes remain, however, which require the Court’s guidance."Source
DOJ-OGR-00019498.jpg
Quote #1
"First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet."Source
DOJ-OGR-00019498.jpg
Quote #2
"Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record."Source
DOJ-OGR-00019498.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,133 characters)
Case 1:20-cr-00330-AJN Document 29 Filed 07/27/20 Page 1 of 4
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Mark S. Cohen
+1 (212) 957-7600
mcohen@cohengresser.com
+1 (212) 957-7600
mcohen@cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
+1 (212) 957-7600
ceverdell@cohengresser.com
July 27, 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:
On behalf of our client, Ghislaine Maxwell, we respectfully request that the Court enter a protective order in the form attached hereto as Exhibit A.
The government has indicated that it requires the entry of a protective order before producing any discovery material to Ms. Maxwell. On July 9, 2020, the government provided defense counsel with an initial draft of a proposed protective order. Since that time, the parties have conferred several times on conference calls and by email, and have been able to reach agreement on almost all of the provisions of the proposed protective order.
Two key disputes remain, however, which require the Court’s guidance. First, the defense believes that potential government witnesses and their counsel should be subject to the same restrictions as the defense concerning appropriate use of the discovery materials—namely, if these individuals are given access to discovery materials during trial preparation, they may not use those materials for any purpose other than preparing for trial in the criminal case, and may not post those materials on the Internet. Second, the defense believes it should not be restricted from publicly disclosing or disseminating the identity of any alleged victims or potential witnesses referenced in the discovery materials who have already identified themselves by speaking on the public record.
As set forth below, we believe that the proposed protective order contains appropriate restrictions that are no broader than necessary to protect the privacy interests of individuals
App.039
DOJ-OGR-00019498
DOJ-OGR-00019498
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document