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682 KB
Extraction Summary
4
People
4
Organizations
3
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing (defense letter to judge)
File Size:
682 KB
Summary
This document is a legal letter filed on October 23, 2020, by attorney Jeffrey Pagliuca on behalf of Ghislaine Maxwell, addressed to Judge Alison J. Nathan. The defense argues that the Government has failed to meet discovery deadlines promised during the July 14, 2020, initial conference, particularly regarding investigative files from the Southern District of Florida. The letter criticizes the Government's recent production as lacking substance, noting it consists largely of civil litigation documents and old records related to Jeffrey Epstein rather than the charged conspiracy.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey Pagliuca | Attorney |
Author of the letter, representing Ghislaine Maxwell, from the firm Haddon, Morgan and Foreman.
|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding over United States v. Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case; the letter argues on her behalf regarding discovery issues.
|
| Jeffrey Epstein | Associate |
Mentioned in relation to discovery documents from the 2000s that the defense claims are irrelevant to the charged con...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
The court where the case is being heard.
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| Government |
Refers to the prosecution/Department of Justice.
|
|
| Southern District of Florida |
Location of a prior investigation mentioned in discovery materials.
|
Timeline (1 events)
2020-07-14
Initial Conference in United States v. Ghislaine Maxwell
Southern District of New York
Locations (3)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
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|
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Address of the United States District Court.
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Jurisdiction of previous investigative files.
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Relationships (2)
Pagliuca is writing on behalf of Maxwell as her legal counsel.
Document mentions discovery materials relating largely to Epstein are being provided in Maxwell's case.
Key Quotes (4)
"Summer is gone, Winter is coming, and the Government has failed to make good on its promises."Source
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Quote #1
"In fact, the promised 'substantial' production of discovery is 'substantial' in size, not substance."Source
DOJ-OGR-00001805.jpg
Quote #2
"The remainder of the discovery contains documents from the 2000s that relate largely to Jeffrey Epstein and therefore have nothing to do with the time period of the conspiracy charged"Source
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Quote #3
"reneging on (or redefining) its assurances to the Court"Source
DOJ-OGR-00001805.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,060 characters)
Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7
HADDON
MORGAN
FOREMAN
MORGAN
FOREMAN
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
Jeffrey Pagliuca
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
October 23, 2020
VIA ECF
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: Response to the Government’s October 7, 2020 letter,
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce “prior investigative files from another investigation in the Southern District of Florida,”¹ which it characterized as part of “the core of the case” against Ms. Maxwell,² after a “careful and exhaustive and through review of all of the materials,” with the “bulk” of the discovery produced by “the end of this summer [2020].”³ Summer is gone, Winter is coming, and the Government has failed to make good on its promises.
Although it casts the October 7, 2020 letter to the Court as a “response to the Court’s prior inquiry regarding” its plan to produce discovery, the Government is, in fact, abandoning the deadlines to which it already agreed and reneging on (or redefining) its assurances to the Court that it would engage in “thoughtful and critical pushing and pressing of questions and issues with respect to actively retrieving any appropriate files.”⁴ In fact, the promised “substantial” production of discovery is “substantial” in size, not substance. Approximately one fourth of the production relates to materials gathered in civil litigation to which Ms. Maxwell was a party. The remainder of the discovery contains documents from the 2000s that relate largely to Jeffrey Epstein and therefore have nothing to do with the time period of the conspiracy charged in the
________________________
¹ July 14, 2020 Tr. p. 12:20-13.
² Id., 12:11.
³ Id., 13:8-14.
⁴ Id., 15:13-18.
¹ July 14, 2020 Tr. p. 12:20-13.
² Id., 12:11.
³ Id., 13:8-14.
⁴ Id., 15:13-18.
DOJ-OGR-00001805
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