052.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 8
- Text status
- Searchable text available
- OCR confidence
- 0.9072238734754114
Original source
Extracted text
Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 1 of 8 Uspc SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 9/2/20 Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca HADDON MORGA e 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmflaw.com [email protected] August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)! United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court’s Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in yyy WM (the “Other Matters”), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically [i Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues ' Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case. DOJ-OGR-00001752
The Honorable Alison J. Nathan August 17, 2020 Page 2 > The items to be referred to (and not filed) are confidential: accordingly, referring to them under seal in the Other Matters will not prejudice the government. Relevant Facts and Procedural History > The Materials to be filed are attached, under seal, as exhibits ggg. Although marked by the government as “Confidential,” the Materials are not “Confidential” as that term has been defined by the Second Circuit. They consist of| a | he Second Circuit has characterized these types of documents as “judicial documents” with a presumptive right of public access. See Brown v. Maxwell, 929 F.3d 41, 47 (2d …
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