EFTA00018881.pdf

67.7 KB

Extraction Summary

4
People
4
Organizations
2
Locations
1
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence
File Size: 67.7 KB
Summary

This document is a letter dated November 3, 2021, from U.S. Attorney Damian Williams to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter submits the parties' joint request to charge and proposed verdict sheet, noting that a redacted version is being docketed publicly to protect third-party privacy interests, while unredacted versions are submitted to the Court. It also mentions the submission of 'Exhibit A' under seal, a document from another case relevant to a defense comment.

People (4)

Name Role Context
Alison J. Nathan Judge
Recipient of the letter; United States District Court Judge.
Ghislaine Maxwell Defendant
Defendant in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).
Damian Williams United States Attorney
Signatory of the letter representing the Government.
Assistant United States Attorneys Prosecutors
Signatories (names redacted) under Damian Williams.

Organizations (4)

Name Type Context
U.S. Department of Justice
United States Attorney's Office
Southern District of New York
United States District Court
Southern District of New York
Second Circuit
Cited in legal precedent (Lugosch v. Pyramid Co. of Onondaga)

Timeline (1 events)

2021-11-03
Government submits joint request to charge and proposed verdict sheet to the Court.
Southern District of New York
Government Defense Judge Nathan

Locations (2)

Location Context
Location of the US Attorney's Office and the District Court.
Jurisdiction

Relationships (2)

Damian Williams Adversarial Ghislaine Maxwell
Prosecutor vs Defendant in United States v. Ghislaine Maxwell
Damian Williams Professional/Legal Alison J. Nathan
Attorney submitting documents to Judge

Key Quotes (4)

"Attached please find the parties’ joint request to charge and proposed verdict sheet."
Source
EFTA00018881.pdf
Quote #1
"The Government is docketing a redacted version today and submitting the unredacted versions to the Court."
Source
EFTA00018881.pdf
Quote #2
"The proposed redactions are narrowly tailored to protect the privacy interests of a third party."
Source
EFTA00018881.pdf
Quote #3
"The Government is also providing under seal Exhibit A, which pertains to a defense comment."
Source
EFTA00018881.pdf
Quote #4

Full Extracted Text

Complete text extracted from the document (1,648 characters)

U.S. Department of Justice
United States Attorney
Southern District of New York
[Redacted]
New York, New York 10007
November 3, 2021
BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
[Redacted]
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Attached please find the parties’ joint request to charge and proposed verdict sheet. The
Government is docketing a redacted version today and submitting the unredacted versions to the
Court. The redline text in the documents reflect the objections of the defense. Further detail of
the parties’ objections are contained in comment bubbles.
The Government has proposed the only redactions in the Request to Charge. These
proposed redactions are consistent with the three-part test articulated by the Second Circuit in
Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government’s
request to charge is a judicial document subject to the common law presumption of access, the
proposed redactions are narrowly tailored to protect the privacy interests of a third party.
The Government is also providing under seal Exhibit A, which pertains to a defense
comment. The defense informs the Government that this exhibit is a document from another case
EFTA00018881
Page 2
that was not itself publicly docketed and therefore is submitting Exhibit A under seal.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
[Redacted]
Assistant United States Attorneys
Southern District of New York
Cc: Defense Counsel (By ECF)
EFTA00018882

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