EFTA00030904.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Motto Building
One Saint Andrew's Plaza
New York. New York 10007
August 12, 2020
VIA EMAIL
Jeffrey S. Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, CO 80203
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Mr. Pagliuca:
The Government writes in response to your letter dated August 9, 2020 requesting to use
discovery materials produced by the Government in the above-referenced criminal case bearing
Bates Nos. SDNY GM _ 00000834 through SDNY_ GM_ 00000962 (the "Unsealing Materials") to
_
litigate a civil lawsuit.
As an initial matter, the Government notes that it remains unclear whether you make this
request in your capacity as defense counsel to Ms. Maxwell in the above-referenced criminal case,
or in your capacity as her attorney in a separate civil matter. If the former, the Government
maintains that the "Confidential" designation of the Unsealing Materials is appropriate because
Chief Judge Colleen McMahon and Magistrate Judge Sarah Netbum have ordered that the
Unsealing Materials remain under seal. The only exceptions to those sealing orders are the
production of Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904
through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the entirety
of the Unsealing Materials to Ms. Maxwell as discovery in the above-referenced criminal case.
The Unsealing Materials relate to an ongoing criminal investigation, and their public disclosure at
this stage risks interference with that investigation. Moreover, the Protective Order issued by
Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all
discovery material produced to the defendant by the Government, regardless of designation,
"[s]hall be used by the Defendant or her Defense Counsel solely for purposes of the defense of this
crimin…

Open in the interactive archive →