SOUTHERN DISTRICT OF NEW YORK
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This document is a Memorandum Opinion and Order from the U.S. District Court, Southern District of New York, dated September 2, 2020. It addresses Defendant Ghislaine Maxwell's motion to modify a protective order to file discovery materials under seal in civil cases. The Court adopts the Government's proposed redactions, citing the need to balance public access with factors like an ongoing grand jury investigation, and orders the parties to confer on further redactions.
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A court order from Judge Alison J. Nathan in the case of USA v. Ghislaine Maxwell, dated August 25, 2020. The judge denies Maxwell's requests to immediately disclose the identities of three alleged victims and to order the BOP to move her to the general population, citing that the request for identities is premature as discovery has just begun.
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This document is a letter motion dated August 24, 2020, from attorney Laura A. Menninger to Judge Alison J. Nathan of the Southern District of New York. The attorney requests permission to file documents under seal on behalf of her client, Ghislaine Maxwell, in the case of United States v. Ghislaine Maxwell. The justification for the request is that the documents contain information designated as confidential by the Government under the terms of the existing Protective Order in the case.
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This document is the final page of a legal filing from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan, dated August 21, 2020. The Government respectfully requests that the Court schedule a date approximately 180 days in the future for them to provide an update on their position regarding the sealing of documents in case 1:20-cr-00330-AJN. The filing is submitted by Acting U.S. Attorney Audrey Strauss and her assistants Maurene Comey, Alison Moe, and Lara Pomerantz.
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This is a legal letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated August 21, 2020, concerning the case against Ghislaine Maxwell. The government requests permission to file the defendant's recent letter with redactions and to file all associated exhibits under seal. The justification for this request is an ongoing grand jury investigation, with the government citing the need to protect confidential materials.
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This is the final page (page 5) of a legal filing by the US Attorney's Office in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The Government argues that the defendant's request to use criminal discovery materials in separate civil cases should be denied because the materials are irrelevant to the civil litigation and the request attempts to bypass a protective order. The Government asserts the defendant is attempting to use these materials merely to attack the Government in a forum where it cannot respond.
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This document is page 3 of a government filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), dated August 21, 2020. The government argues against modifying a protective order, asserting that the defendant should not be allowed to use discovery materials from this criminal case in her parallel civil cases. The filing highlights that the grand jury investigation into Epstein's co-conspirators is active and ongoing, and that disseminating these materials could compromise witness privacy and the investigation.
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This document is a "Notice of Appearance" filed on August 20, 2020, in the U.S. District Court for the Southern District of New York for the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). Assistant U.S. Attorney Lara Pomerantz, on behalf of Acting U.S. Attorney Audrey Strauss, formally notifies the court of her appearance in the case and requests to be added as a Filing User for electronic notifications.
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This is a court order issued by Judge Alison J. Nathan on August 18, 2020, in the case of United States v. Ghislaine Maxwell. The order establishes a briefing schedule for a letter motion filed by the Defendant on August 17, 2020, which seeks to modify a protective order and be filed under seal. The Government's opposition is due by August 21, and the Defendant's reply is due by August 24.
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This legal document, filed on August 13, 2020, is a response from the U.S. Attorney's Office for the Southern District of New York to a defendant's requests regarding housing and access to discovery. The prosecution argues that the defendant's application is moot because the Bureau of Prisons (BOP) has already granted the defendant extensive daily access to discovery materials from 7:00 a.m. to 8:00 p.m. The document concludes by requesting that the defendant's application be denied.
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This legal document is a letter dated August 13, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution is opposing recent requests from the defendant, Ghislaine Maxwell, for an early disclosure of government witnesses and for the court to intervene with the Bureau of Prisons. The government argues these requests are premature and meritless, citing the early stage of discovery and previous denials of similar applications by the court.
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This is a letter motion dated August 10, 2020, from Ghislaine Maxwell's defense attorneys (Cohen & Gresser LLP) to Judge Alison J. Nathan. The defense is requesting two court orders: one to compel the government to disclose the identities of 'Victims 1-3' mentioned in the indictment, and another to direct the Bureau of Prisons to move Maxwell to the general population to facilitate access to discovery materials. The document includes a handwritten and stamped order from Judge Nathan dated August 11, 2020, setting a deadline of August 13 for the government's response.
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This document is an affidavit filed on August 10, 2020, by Christian R. Everdell, an attorney for Ghislaine Maxwell, in the case of United States v. Ghislaine Maxwell. Everdell certifies that the defense counsel has conferred with the prosecution regarding a request to disclose the identities of 'Victims 1-3'. The government denied the immediate request, indicating the identities would be disclosed later as part of the standard discovery process.
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This legal document is a court order issued by United States District Judge Alison J. Nathan on July 30, 2020. The order resolves a dispute in case 1:20-cr-00330-AJN by adopting the Government's proposed protective order and rejecting the Defense's request for further restrictions on discovery materials as unwarranted and unprecedented.
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This document is a Memorandum Opinion & Order filed on July 30, 2020, in the case of United States v. Ghislaine Maxwell in the Southern District of New York. Judge Alison J. Nathan addresses a dispute over a protective order, ultimately adopting the Government's proposed version over Maxwell's requests to publicly reference alleged victims and restrict Government witnesses' use of discovery materials. The document cites legal standards for protective orders under Federal Rule of Criminal Procedure 16(d)(1).
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This document is the first page of a Protective Order filed on July 30, 2020, in the Southern District of New York case against Ghislaine Maxwell. Judge Alison J. Nathan outlines that the Government intends to produce discovery materials that are sensitive, relate to ongoing investigations, or contain personal identifying information. The order is designed to prevent premature disclosure or public dissemination of these materials to protect privacy and the integrity of the ongoing investigation.
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This document is an Affidavit of Certification filed on July 28, 2020, in the criminal case of U.S. v. Ghislaine Maxwell. Assistant U.S. Attorney Alex Rossmiller affirms that the prosecution and defense have conferred on a proposed protective order but have been unable to resolve two areas of dispute. The first point of contention involves the defense's objection to the government's proposal regarding the referencing of witness and victim identities.
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This document is the first page of a [Proposed] Protective Order filed on July 28, 2020, in the United States District Court for the Southern District of New York, case number 20 Cr. 330 (AJN), United States of America v. Ghislaine Maxwell. Judge Alison J. Nathan presides over the document, which outlines the Government's intent to produce discovery materials to the defendant while restricting their dissemination to protect privacy, ongoing investigations, and prevent prejudicial pretrial publicity due to the sensitive nature of the information.
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This legal document, filed on July 28, 2020, is the U.S. Government's response to a defendant's motion in a criminal case. The Government argues against the defendant's attempt to restrict its use of gathered materials and to impose restrictions on third parties, calling the request unprecedented and without legal basis. The filing, submitted by Acting U.S. Attorney Audrey Strauss to Judge Alison J. Nathan, urges the court to deny the defendant's motion and implement the Government's own proposed protective order.
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This legal document is a letter dated July 27, 2020, from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests an opportunity to respond to a motion for a protective order filed that morning by the defense counsel for Ghislaine Maxwell. The letter notes that the defense's filing was a surprise, as the Government believed discussions to jointly propose a protective order were still ongoing.
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This document is an Affidavit of Certification filed on July 27, 2020, by Christian R. Everdell, defense attorney for Ghislaine Maxwell. Everdell certifies that the defense has conferred with federal prosecutors (Moe, Rossmiller, and Comey) regarding a protective order but remains in dispute regarding restrictions on government witnesses' use of discovery materials.
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This document is a proposed protective order for the criminal case of United States v. Ghislaine Maxwell, filed in the Southern District of New York on July 27, 2020. The order aims to manage the disclosure of sensitive materials from the government to the defense during the discovery process. It seeks to protect the privacy of individuals, prevent impediment to the ongoing investigation, and avoid prejudicial pretrial publicity by controlling the dissemination of confidential information.
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This is a letter dated July 27, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan of the Southern District of New York. The attorneys request the court to enter a protective order for discovery materials in the case of United States v. Ghislaine Maxwell. The letter highlights that while most terms have been agreed upon with the government, two key disputes remain: whether government witnesses should face the same restrictions as the defense regarding discovery materials, and whether the defense should be allowed to identify alleged victims or witnesses who are already public.
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This document is the final signature page (page 7 of 7) of a legal filing dated July 21, 2020, for Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is submitted by attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan, with copies sent to prosecutors at the SDNY (Moe, Rossmiller, Comey) and other defense counsel (Cohen, Everdell, Menninger).
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This is a legal letter dated July 21, 2020, from Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C., to Judge Alison J. Nathan of the Southern District of New York. The attorney, representing defendant Ghislaine Maxwell, requests that the court issue an order prohibiting the U.S. Government and its affiliates from making extrajudicial statements about the case, arguing such statements are prejudicial and violate Maxwell's Sixth Amendment right to a fair trial.
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