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699 KB

Extraction Summary

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People
4
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal brief / court filing (appellate)
File Size: 699 KB
Summary

This document is page 13 of a legal filing (Case 20-3061) dated October 8, 2020, concerning Ghislaine Maxwell. It argues that releasing deposition material prematurely would compromise her ability to make a 'Martindell argument' and discusses her intent to move Judge Preska to stay unsealing pending her criminal case. The text highlights a conflict where Maxwell claims she cannot fairly argue her case because Judge Preska and the appellate panel are unaware of redacted facts regarding government proceedings and subpoenas.

People (3)

Name Role Context
Ghislaine Maxwell Defendant/Appellant
Subject of the legal arguments regarding unsealing of deposition materials and criminal case proceedings.
Loretta Preska Judge
Referred to as 'Judge Preska'; presiding over the unsealing matters.
Alison Nathan Judge
Referred to as 'Judge Nathan'; presiding over the criminal case; issued an order limiting what Maxwell can share.

Organizations (4)

Name Type Context
The Government
Prosecution/DOJ; opposing Maxwell's motions.
Court-1
Anonymized court that issued an order regarding a subpoena.
Court-2
Anonymized court mentioned in relation to sharing identities.
DOJ-OGR
Department of Justice - Office of Government Information Services (implied by footer stamp).

Timeline (2 events)

2020-10-08
Filing of Document 94 in Case 20-3061
Court of Appeals (implied by 'panel of this Court')
Future/Intended
Motion to stay future unsealing pending outcome of criminal case
Court
Ghislaine Maxwell Judge Preska

Relationships (2)

Ghislaine Maxwell Adversarial/Legal The Government
Government opposes Maxwell's motions; Maxwell challenges Government's conduct.
Judge Preska Judicial Colleagues Judge Nathan
Both judges are handling different aspects (civil/unsealing vs criminal) of legal matters involving Maxwell.

Key Quotes (4)

"deposition material is prematurely released, as the government so clearly desires, Ms. Maxwell’s ability to make the Martindell argument will be compromised."
Source
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Quote #1
"Judge Preska and the panel of this Court deciding the unsealing appeal are the only relevant actors who don’t know the relevant facts."
Source
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Quote #2
"Surely due process does not contemplate a scenario in which Ms. Maxwell is never permitted to challenge [REDACTED]."
Source
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Quote #3
"And if Judge Preska’s unsealing order goes into effect, the government will seek to deny Ms. Maxwell the right to challenge its conduct before Judge Nathan."
Source
DOJ-OGR-00019659.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,642 characters)

Case 20-3061, Document 94, 10/08/2020, 2948481, Page13 of 23
deposition material is prematurely released, as the government so clearly desires,
Ms. Maxwell’s ability to make the Martindell argument will be compromised.³
Third, Ms. Maxwell intends to move Judge Preska to stay future unsealing
pending the outcome of the criminal case. But she cannot fairly make her case to
Judge Preska unless Judge Preska knows [REDACTED]
[REDACTED] Judge Preska and the panel
of this Court deciding the unsealing appeal are the only relevant actors who don’t
know the relevant facts.
The government’s second contention—that Ms. Maxwell can already share
the “basic facts” with Judge Preska—misunderstands what Ms. Maxwell seeks to
share (under seal and not publicly) and what Judge Nathan’s order permits (not
very much). According to the government, Ms. Maxwell is free to share the
identity of “Court-1” and “Court-2” and
the fact that the Government obtained an order from Court-1
permitting the Recipient to comply with a subpoena for materials
________________________________________________________________
³ Surely due process does not contemplate a scenario in which Ms. Maxwell
is never permitted to challenge [REDACTED]
[REDACTED]. But that’s apparently the government’s position. Ms. Maxwell
did not know of the [REDACTED] proceeding before [REDACTED], so she
couldn’t argue against [REDACTED]. Ms. Maxwell did not know
when [REDACTED], so she couldn’t appeal.
And if Judge Preska’s unsealing order goes into effect, the government will seek to
deny Ms. Maxwell the right to challenge its conduct before Judge Nathan.
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DOJ-OGR-00019659

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