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631 KB
Extraction Summary
6
People
3
Organizations
1
Locations
0
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (court motion/submission)
File Size:
631 KB
Summary
This document is page 3 of a legal filing submitted on October 7, 2020, by the Acting US Attorney Audrey Strauss and Assistant US Attorneys (Comey, Moe, Pomerantz) in the Southern District of New York (Case 1:20-cr-00330-AJN). The Government argues against the premature disclosure of witness identities and sensitive materials to the defense, citing risks to the ongoing investigation and the potential to deter other victims from coming forward. They request the Court to approve a delay in disclosing these materials pursuant to Rule 16(d).
People (6)
| Name | Role | Context |
|---|---|---|
| Audrey Strauss | Acting United States Attorney |
Signatory of the document representing the Government.
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| Maurene Comey | Assistant United States Attorney |
Signatory/Attorney for the Government (SDNY).
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| Alison Moe | Assistant United States Attorney |
Signatory/Attorney for the Government (SDNY).
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| Lara Pomerantz | Assistant United States Attorney |
Signatory/Attorney for the Government (SDNY).
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| The Defendant | Defendant |
Referenced in the text as the party to whom disclosure is being delayed. (Contextually Ghislaine Maxwell based on Cas...
|
| Unnamed Witnesses/Victims | Witnesses/Victims |
Individuals whose identities the Government seeks to protect from premature disclosure.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States Government |
The prosecution/plaintiff in the case.
|
|
| Southern District of New York |
The jurisdiction handling the case.
|
|
| The Court |
The judicial body being petitioned.
|
Locations (1)
| Location | Context |
|---|---|
|
Location of the US Attorney's office handling the case.
|
Relationships (2)
Both listed as attorneys for the Southern District of New York on the signature block.
Government is prosecuting the defendant and arguing against immediate disclosure of evidence to them.
Key Quotes (4)
"Premature disclosure of these witnesses’ identities and sensitive information about those witnesses risks jeopardizing the Government’s ongoing investigation in at least two respects."Source
DOJ-OGR-00001786.jpg
Quote #1
"Second, an order requiring the immediate production of these Materials would risk deterring other victims from coming forward to be interviewed and from providing evidence to the Government."Source
DOJ-OGR-00001786.jpg
Quote #2
"Victims who may be considering cooperating with the Government’s investigation may decline to do so if they believe that the information they provide... must be immediately disclosed to the defense in this case."Source
DOJ-OGR-00001786.jpg
Quote #3
"Accordingly, the Government respectfully requests that the Court approve the Government’s request to delay disclosure of these Materials."Source
DOJ-OGR-00001786.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,733 characters)
Case 1:20-cr-00330-AJN Document 60 Filed 10/07/20 Page 3 of 3
Page 3
Page 3
Government as part of its ongoing investigation, well in advance of any trial in this matter.
Premature disclosure of these witnesses’ identities and sensitive information about those witnesses risks jeopardizing the Government’s ongoing investigation in at least two respects. First, disclosure would tend to reveal to the defendant the scope of and evidence gathered during the Government’s ongoing investigation, the details of which are not currently public or known to the defendant. Second, an order requiring the immediate production of these Materials would risk deterring other victims from coming forward to be interviewed and from providing evidence to the Government. Victims who may be considering cooperating with the Government’s investigation may decline to do so if they believe that the information they provide—even information outside the period charged in the Indictment—must be immediately disclosed to the defense in this case. Given the sensitivity of the Materials, the need to protect the Government’s ongoing investigation, and the minimal (if any) relevance of the Materials to the offenses charged in the Indictment, the Government respectfully submits that good cause exists pursuant to Rule 16(d) to delay their disclosure.
Premature disclosure of these witnesses’ identities and sensitive information about those witnesses risks jeopardizing the Government’s ongoing investigation in at least two respects. First, disclosure would tend to reveal to the defendant the scope of and evidence gathered during the Government’s ongoing investigation, the details of which are not currently public or known to the defendant. Second, an order requiring the immediate production of these Materials would risk deterring other victims from coming forward to be interviewed and from providing evidence to the Government. Victims who may be considering cooperating with the Government’s investigation may decline to do so if they believe that the information they provide—even information outside the period charged in the Indictment—must be immediately disclosed to the defense in this case. Given the sensitivity of the Materials, the need to protect the Government’s ongoing investigation, and the minimal (if any) relevance of the Materials to the offenses charged in the Indictment, the Government respectfully submits that good cause exists pursuant to Rule 16(d) to delay their disclosure.
Accordingly, the Government respectfully requests that the Court approve the Government’s request to delay disclosure of these Materials.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
Acting United States Attorney
By: [Signature]
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Maurene Comey / Alison Moe / Lara Pomerantz
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Cc: All Counsel of Record (By ECF)
DOJ-OGR-00001786
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