DOJ-OGR-00019563.jpg
509 KB
Extraction Summary
3
People
3
Organizations
2
Locations
3
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / letter motion
File Size:
509 KB
Summary
This document is a letter motion filed on September 2, 2020 (dated August 17), from Ghislaine Maxwell's attorney, Jeffrey Pagliuca, to Judge Alison J. Nathan. Maxwell requests permission to use specific discovery materials produced by the government in early August 2020 in redacted 'Other Matters' (likely separate legal proceedings). The document contains significant redactions concealing the specific nature of these other matters and the content of the discovery materials.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Pagliuca | Attorney |
Author of the letter, representing Ghislaine Maxwell, from the firm Haddon, Morgan and Foreman, P.C.
|
| Alison J. Nathan | Judge |
Recipient of the letter, United States District Court Judge.
|
| Ghislaine Maxwell | Defendant |
Subject of the legal motion, requesting modification of a protective order.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. |
Firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
Jurisdiction where the case is being heard.
|
|
| US Government |
Referenced as 'the government' which produced discovery materials.
|
Timeline (3 events)
August 13, 2020
August 5, 2020
Locations (2)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of the United States District Court, SDNY.
|
Relationships (1)
Pagliuca is writing the motion on behalf of Defendant Ghislaine Maxwell.
Key Quotes (2)
"Defendant Ghislaine Maxwell... requests that the Court enter an Order allowing her to refer to and file under seal in [REDACTED] (the 'Other Matters'), certain discovery materials produced by the government on August 5, 2020."Source
DOJ-OGR-00019563.jpg
Quote #1
"Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues [REDACTED]"Source
DOJ-OGR-00019563.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,395 characters)
Case 1:20-cr-00330-AJN Document 320 Filed 09/02/20 Page 1 of 3
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/2/20
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/2/20
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
Jeffrey Pagliuca
H A D D O N
M O R G A N
F O R E M A N
M O R G A N
F O R E M A N
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
August 17, 2020
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Request to Modify Protective Order (UNDER SEAL)¹
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court’s Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in █
█ (the “Other Matters”), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically █ ²
█ (the “Other Matters”), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically █ ²
Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues █
█
█
█
█
__________________
¹ Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case.
¹ Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case.
2 █
█
█
█
█
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█
App.104
DOJ-OGR-00019563
DOJ-OGR-00019563
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