DOJ-OGR-00005378.jpg

446 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / court filing letter
File Size: 446 KB
Summary

This document is a legal letter dated October 25, 2021, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. Pagliuca informs the court that the defense has filed an Omnibus Response to the Government's Motions in Limine under seal to allow time to review for necessary redactions, with a public filing and justification letter to follow by October 29, 2021.

People (3)

Name Role Context
Jeffrey S. Pagliuca Defense Attorney
Author of the letter; counsel for Ghislaine Maxwell from the firm Haddon, Morgan and Foreman, P.C.
Alison J. Nathan Judge
Recipient of the letter; presiding judge for the Southern District of New York.
Ghislaine Maxwell Defendant
Subject of the case (United States v. Ghislaine Maxwell); the client represented by Pagliuca.

Organizations (3)

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 handling the case.
Department of Justice (DOJ)
Implied by the OGR (Office of Government Relations) Bates stamp in the footer.

Timeline (2 events)

October 25, 2021
Filing of Omnibus Response to the Government's Motions in Limine (filed temporarily under seal).
United States District Court, SDNY
Counsel for Ghislaine Maxwell
October 29, 2021
Deadline for filing the Response on the public docket with proposed redactions and a joint letter justifying them.
United States District Court, SDNY
Counsel for Ghislaine Maxwell

Locations (2)

Location Context
Address of Haddon, Morgan and Foreman, P.C.
Address of the United States District Court.

Relationships (2)

Jeffrey S. Pagliuca Attorney-Client Ghislaine Maxwell
Letter explicitly states 'counsel for Ghislaine Maxwell' and is signed by Jeffrey S. Pagliuca.
Alison J. Nathan Judge-Defendant Ghislaine Maxwell
Letter addresses Judge Nathan regarding United States v. Ghislaine Maxwell.

Key Quotes (2)

"Today, counsel for Ghislaine Maxwell filed her Omnibus Response to the Government's Motions in Limine temporarily under seal in order to provide the parties time to consider whether any proposed redactions can be justified under the relevant legal test."
Source
DOJ-OGR-00005378.jpg
Quote #1
"Consistent with the Court's Order of today (Dkt. 368), counsel for Ms. Maxwell will file this Response together with her other pleadings regarding in limine issues on the public docket..."
Source
DOJ-OGR-00005378.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,156 characters)

Case 1:20-cr-00330-PAE Document 370 Filed 10/25/21 Page 1 of 1
H A D D O N
M O R G A N
F O R E M A N
Haddon, Morgan and Foreman, P.C
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
October 25, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Today, counsel for Ghislaine Maxwell filed her Omnibus Response to the Government's Motions in Limine temporarily under seal in order to provide the parties time to consider whether any proposed redactions can be justified under the relevant legal test.
Consistent with the Court's Order of today (Dkt. 368), counsel for Ms. Maxwell will file this Response together with her other pleadings regarding in limine issues on the public docket with any proposed redactions and a joint letter justifying any such redactions on or before October 29, 2021.
Respectfully Submitted,
[Signature]
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00005378

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