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653 KB

Extraction Summary

3
People
2
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing / court document (government response regarding redactions)
File Size: 653 KB
Summary

This document is page 2 of a Government filing from February 16, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The Government argues against the defendant's requests to redact specific information from a briefing, including arguments about the jury pool composition (specifically regarding sexual abuse survivors), investigative steps taken by the defense, the defense's view of underlying facts, and discovery requests. The Government asserts these redactions are not authorized by the Court's previous orders or are not narrowly tailored.

People (3)

Name Role Context
The Defendant Defendant
Refers to Ghislaine Maxwell (based on Case 1:20-cr-00330-PAE); seeking various redactions to a legal briefing.
Juror 50 Juror
Subject of a questionnaire; discussions regarding this juror are a point of contention for redaction.
The Government Prosecution
The party filing this document, opposing the defendant's redaction requests.

Organizations (2)

Name Type Context
The Court
US District Court (SDNY); responsible for issuing orders regarding redactions.
DOJ
Department of Justice (referenced in footer DOJ-OGR-00008964).

Timeline (2 events)

Future (relative to doc)
Hearing regarding requested discovery
Court
Prior to 2022-02-16
Jury Selection
Court
The Court Prospective Jurors

Relationships (2)

The Defendant Legal Adversaries The Government
Government opposes defendant's redaction requests throughout the document.
Juror 50 Trial Participant The Defendant
Defendant seeks to redact discussions related to Juror 50's questionnaire.

Key Quotes (4)

"The defendant seeks to redact legal arguments about how the Court addressed during jury selection the multiple prospective jurors who disclosed experiencing sexual abuse, assault, or harassment."
Source
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Quote #1
"The defendant seeks to redact '[d]etails of investigative steps the defense has taken and evidence uncovered thus far.'"
Source
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Quote #2
"The Court expressly ordered that the parties should not redact legal arguments or discussions of publicly available facts, which is exactly what the defendant now proposes to do."
Source
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Quote #3
"The defendant seeks to redact discussions of her 'requested discovery in advance of the hearing.'"
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (1,897 characters)

Case 1:20-cr-00330-PAE Document 603 Filed 02/16/22 Page 2 of 3
Page 2
for public access to those questionnaires. Accordingly, it is not necessary to redact discussions of Juror 50’s questionnaire from the briefing.
• The defendant seeks to redact legal arguments about the statistical composition of the jury pool. In particular, the defendant seeks to redact legal arguments about how the Court addressed during jury selection the multiple prospective jurors who disclosed experiencing sexual abuse, assault, or harassment. These redactions are not contemplated by the Court’s Order. While quotations or discussions of specific sealed juror materials may be redacted, there is no basis to redact legal arguments about the jury pool as a whole.
• The defendant seeks to redact “[d]etails of investigative steps the defense has taken and evidence uncovered thus far.” (Dkt. No. 602). As an initial matter, the Government notes the defense briefing contains very minimal non-public information. To the extent any of the defendant’s proposed redactions address non-public materials, the Court has authorized such redactions.
• The defendant seeks to redact “[t]he defense’s view of the underlying facts.” (Dkt. No. 602). But the Court expressly ordered that the parties should not redact legal arguments or discussions of publicly available facts, which is exactly what the defendant now proposes to do. (Dkt. No. 596 at 4). The Court has already ruled that these proposed redactions are not narrowly tailored.
• The defendant seeks to redact discussions of her “requested discovery in advance of the hearing.” (Dkt. No. 602). The Court did not authorize this category of redactions. Moreover, the defendant does not offer any justification for her request, and the Government sees none.
In addition, the Government notes that the defendant has proposed redactions to portions
DOJ-OGR-00008964

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