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559 KB
Extraction Summary
3
People
3
Organizations
5
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
559 KB
Summary
This document is a letter dated October 14, 2021, from attorney Jeffrey Pagliuca to Judge Alison J. Nathan, confirming November 15, 2021, as the deadline for Ghislaine Maxwell to file a motion under Federal Rule of Evidence 412 concerning the admissibility of evidence of an alleged victim's sexual behavior, clarifying its distinction from a motion in limine and its specific procedural requirements.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Pagliuca | Attorney |
From Haddon, Morgan and Foreman, P.C., writing the letter.
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| Alison J. Nathan | The Honorable Judge |
Addressee of the letter, United States District Court, Southern District of New York.
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| Ghislaine Maxwell | Defendant |
The subject of the legal case, 20 Cr. 330 (AJN).
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. |
Law firm of Jeffrey Pagliuca, sender of the letter.
|
|
| United States District Court, Southern District of New York |
Court where the case United States v. Ghislaine Maxwell is being heard.
|
|
| Black's Law Dictionary |
Cited legal reference (11th ed. 2019).
|
Timeline (3 events)
November 15, 2021
Deadline for Ghislaine Maxwell to file a motion under Federal Rule of Evidence 412.
October 14, 2021
Letter written and filed via ECF regarding the deadline for a Rule 412 motion in the Ghislaine Maxwell case.
Locations (5)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
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Address of the United States District Court, Southern District of New York.
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City of Haddon, Morgan and Foreman, P.C.
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State of Haddon, Morgan and Foreman, P.C.
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City and State of the United States District Court.
|
Relationships (2)
Jeffrey Pagliuca wrote a letter to Judge Alison J. Nathan.
Maxwell is the defendant in a case presided over by Judge Nathan.
Key Quotes (4)
"I write to confirm that November 15, 2021 is the deadline for Ms. Maxwell to file a motion under Federal Rule of Evidence 412, which governs the admissibility of evidence of an alleged victim's sexual behavior."Source
DOJ-OGR-00005226.jpg
Quote #1
"A motion in limine is a "pretrial request that certain inadmissible evidence not be referred to or offered at trial.""Source
DOJ-OGR-00005226.jpg
Quote #2
"A motion under Rule 412 is not a motion in limine. Rather, it is a motion seeking permission to admit evidence the Rules of Evidence might otherwise exclude."Source
DOJ-OGR-00005226.jpg
Quote #3
"Fed. R. Evid. 412(c)(1)(B) (providing that a defendant must file her motion "at least 14 days before trial unless the court, for good cause, sets a different time")."Source
DOJ-OGR-00005226.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,583 characters)
Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21
HADDON
MORGAN
FOREMAN
Page 1 of 3
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
October 14, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:
Deadline for Filing Motion under Federal Rule of Evidence 412,
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write to confirm that November 15, 2021 is the deadline for Ms. Maxwell to file a
motion under Federal Rule of Evidence 412, which governs the admissibility of evidence of an
alleged victim's sexual behavior.
Under this Court's pretrial scheduling order, motions in limine are due on October 18. A
motion in limine is a "pretrial request that certain inadmissible evidence not be referred to or
offered at trial." Black's Law Dictionary (11th ed. 2019).
A motion under Rule 412 is not a motion in limine. Rather, it is a motion seeking
permission to admit evidence the Rules of Evidence might otherwise exclude. It is a substantive
motion under a specific rule of evidence with specific procedures for its filing, consideration, and
determination. Fed. R. Evid. 412(c). And the Rule itself sets a deadline for filing a motion under
its terms—14 days before trial. Fed. R. Evid. 412(c)(1)(B) (providing that a defendant must file
her motion "at least 14 days before trial unless the court, for good cause, sets a different time").
DOJ-OGR-00005226
HADDON
MORGAN
FOREMAN
Page 1 of 3
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
October 14, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:
Deadline for Filing Motion under Federal Rule of Evidence 412,
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write to confirm that November 15, 2021 is the deadline for Ms. Maxwell to file a
motion under Federal Rule of Evidence 412, which governs the admissibility of evidence of an
alleged victim's sexual behavior.
Under this Court's pretrial scheduling order, motions in limine are due on October 18. A
motion in limine is a "pretrial request that certain inadmissible evidence not be referred to or
offered at trial." Black's Law Dictionary (11th ed. 2019).
A motion under Rule 412 is not a motion in limine. Rather, it is a motion seeking
permission to admit evidence the Rules of Evidence might otherwise exclude. It is a substantive
motion under a specific rule of evidence with specific procedures for its filing, consideration, and
determination. Fed. R. Evid. 412(c). And the Rule itself sets a deadline for filing a motion under
its terms—14 days before trial. Fed. R. Evid. 412(c)(1)(B) (providing that a defendant must file
her motion "at least 14 days before trial unless the court, for good cause, sets a different time").
DOJ-OGR-00005226
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