Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 1 of 8
Cy
HADDON
MORGAN
FOREMAN
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
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #; |
DATE FILED: 9/2/20
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
[email protected]
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, specifica]! y [I
Disclosure to the judicial officers in the Other Matters is necessary for fair determination of
important iste [I
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.
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DOJ-OGR-00001752