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789 KB
Extraction Summary
3
People
2
Organizations
0
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (letter motion excerpt)
File Size:
789 KB
Summary
This is page 5 of a legal filing dated August 17, 2020, addressed to Judge Alison J. Nathan regarding United States v. Ghislaine Maxwell. The defense argues that the government may have violated the spirit of a Protective Order by providing a sealed order to a redacted third party, contradicting previous assurances made by Alex Rossmiller that such sharing would not occur. The document highlights concerns about the impact on Maxwell's constitutional rights and impending civil litigation.
People (3)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | Judge |
Recipient of the letter; The Honorable Judge presiding over the case.
|
| Ghislaine Maxwell | Defendant/Accused |
Referred to as 'Ms. Maxwell'; the subject of the legal defense and protective order discussion.
|
| Alex Rossmiller | Prosecutor (implied) |
Cited as the author of a letter (Doc. # 33) making representations on behalf of the government regarding discovery ma...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Refers to the prosecution/DOJ.
|
|
| The Court |
United States District Court (Southern District of New York, implied by Case No and Judge Nathan).
|
Relationships (1)
Legal filing discussing rights of the accused and protective orders against the government.
Key Quotes (3)
"These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt."Source
DOJ-OGR-00019567.jpg
Quote #1
"“the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.”"Source
DOJ-OGR-00019567.jpg
Quote #2
"Yet as described above, the government must have given a copy of the sealed order to [REDACTED]"Source
DOJ-OGR-00019567.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,146 characters)
Case 1:20-cr-00330-AJN Document 32 Filed 08/17/20 Page 5 of 5
The Honorable Alison J. Nathan
August 17, 2020
Page 5
August 17, 2020
Page 5
parte application. [REDACTED] denied the application. [REDACTED] 7
[REDACTED].
[REDACTED].
Counsel for Ms. Maxwell then learned, [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
The pressing issue that necessitates the filing of this request concerns [REDACTED]
[REDACTED]
These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt.
[REDACTED]
These issues, in turn, impact her rights as the accused in this matter, constitutionally presumed innocent unless and until the government proves her guilt beyond all reasonable doubt.
The Protective Order in this case
The Protective Order in this case prohibits the use of the discovery materials or confidential-designated materials “for any civil proceeding or any purpose other than the defense of this action” absent mutual agreement in writing between the government and defense counsel or if “modified by further order of the Court.” Doc. # 36 at ¶¶ 1(a), 10(a), 18. Ms. Maxwell agreed to that limitation after assurances by the government, consistent with their representation to this Court, that “the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.” Letter of Alex Rossmiller at 6 (Doc. # 33) (July 28, 2020). This Court relied on that representation in its ruling that government witnesses should not be limited in their use of materials gained from the government in any related civil litigation. Memorandum Op’n & Order at 3 (July 30, 2020). Yet as described above, the government must have given a copy of the sealed order to [REDACTED]
[REDACTED]
[REDACTED]
The Protective Order in this case prohibits the use of the discovery materials or confidential-designated materials “for any civil proceeding or any purpose other than the defense of this action” absent mutual agreement in writing between the government and defense counsel or if “modified by further order of the Court.” Doc. # 36 at ¶¶ 1(a), 10(a), 18. Ms. Maxwell agreed to that limitation after assurances by the government, consistent with their representation to this Court, that “the Government rarely provides any third party, including a witness, with any material they did not already possess,” and therefore “concerns defense counsel raises about future use in civil litigation are not likely to occur.” Letter of Alex Rossmiller at 6 (Doc. # 33) (July 28, 2020). This Court relied on that representation in its ruling that government witnesses should not be limited in their use of materials gained from the government in any related civil litigation. Memorandum Op’n & Order at 3 (July 30, 2020). Yet as described above, the government must have given a copy of the sealed order to [REDACTED]
[REDACTED]
[REDACTED]
Paragraph 18 of the Protective Order permits modification by the Court. Further, any concerns that the government may raise concerning their on-going grand jury investigation will be obviated by submission of these materials under seal in the other matters.
The reasons this Court should grant the request
[REDACTED]
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________
7 [REDACTED]
[REDACTED]
7 [REDACTED]
[REDACTED]
App.108
DOJ-OGR-00019567
DOJ-OGR-00019567
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