DOJ-OGR-00001713.jpg
844 KB
Extraction Summary
5
People
4
Organizations
3
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court order
File Size:
844 KB
Summary
This is a letter motion dated August 10, 2020, from Ghislaine Maxwell's defense attorneys (Cohen & Gresser LLP) to Judge Alison J. Nathan. The defense is requesting two court orders: one to compel the government to disclose the identities of 'Victims 1-3' mentioned in the indictment, and another to direct the Bureau of Prisons to move Maxwell to the general population to facilitate access to discovery materials. The document includes a handwritten and stamped order from Judge Nathan dated August 11, 2020, setting a deadline of August 13 for the government's response.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Client of Cohen & Gresser; subject of the indictment; detained.
|
| Alison J. Nathan | Judge (U.S.D.J.) |
Judge presiding over the case; signed the order on the document.
|
| Mark S. Cohen | Attorney |
Defense counsel for Ghislaine Maxwell; partner at Cohen & Gresser LLP.
|
| Christian R. Everdell | Attorney |
Defense counsel for Ghislaine Maxwell; partner at Cohen & Gresser LLP.
|
| Victims 1-3 | Alleged Victims |
Anonymous individuals referenced in the indictment whose identities the defense is seeking.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Legal representation for the defendant.
|
|
| United States District Court Southern District of New York |
Venue for the legal proceedings.
|
|
| Bureau of Prisons |
Agency detaining Maxwell; defense is requesting they release her into general population.
|
|
| The Government |
Opposing party in United States v. Ghislaine Maxwell.
|
Timeline (3 events)
August 13, 2020
Locations (3)
| Location | Context |
|---|---|
|
Jurisdiction of the court.
|
|
|
Address of the United States Courthouse.
|
|
|
Address of Cohen & Gresser LLP.
|
Relationships (2)
Letter states 'On behalf of our client, Ghislaine Maxwell'
Letter states 'On behalf of our client, Ghislaine Maxwell'
Key Quotes (3)
"First, we request that the Court enter an order directing the government to disclose to defense counsel the identities of the three alleged victims referenced in the indictment ('Victims 1-3')..."Source
DOJ-OGR-00001713.jpg
Quote #1
"Second, we request that the Court enter an order directing the Bureau of Prisons ('BOP') to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials..."Source
DOJ-OGR-00001713.jpg
Quote #2
"The Government is hereby ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020."Source
DOJ-OGR-00001713.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,591 characters)
Case 1:20-cr-00330-AJN Document 30 Filed 08/10/20 Page 1 of 6
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
C&G COHEN & GRESSER LLP
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
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/11/20
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/11/20
August 10, 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
SO ORDERED. 8/11/20
[Signature]
Alison J. Nathan, U.S.D.J.
[Signature]
Alison J. Nathan, U.S.D.J.
[Boxed Text]
The Government is hereby ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020. The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
SO ORDERED.
[End Boxed Text]
The Government is hereby ORDERED to respond to the Defendant's letter motion by Thursday, August 13, 2020. The Defendant's reply, if any, is due on or before Monday, August 17, 2020.
SO ORDERED.
[End Boxed Text]
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion seeking the Court’s assistance with two critical issues that greatly impact Ms. Maxwell’s ability to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an order directing the government to disclose to defense counsel the identities of the three alleged victims referenced in the indictment (“Victims 1-3”), subject to the restrictions of the protective order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully investigate the alleged conduct, which is now over 25 years old. Second, we request that the Court enter an order directing the Bureau of Prisons (“BOP”) to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is detained so that she can meaningfully participate in the preparation of her defense.
1. Disclosure of Victim Identities
The Court should order the government to disclose the identities of Victims 1-3 to defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot prepare for or receive a fair trial without this information. Moreover, the requested disclosure is authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the circumstances of this case.
Here, it is clear from the face of the indictment that the government’s case is based on the accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is therefore critical for the defense to know the names of these individuals as soon as possible, so
DOJ-OGR-00001713
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