Case 1:20-cr-00330-AJN Document 54 Filed 09/08/20 Page 1 of 6
Ie
E Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
HADDON
tener Loctite 150 East 10th Avenue
FOREMAN Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmflaw.com
[email protected]
August 24, 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: Reply in Support of Request to Modify Protective Order (Under Seal)!
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal
to (the “Civil
ee
Litigation”) the fact that her adversary i already handed
over
ee
Ml. to the U.S. Attorney’s Office pursuant to a subpoena 9
es
The government proposes to keep in the dark about the fact and method of the
disclosure. They claim the civil litigation 1s “unrelated,” that issuance of the subpoena was
“standard practice,” and that disclosure will jeopardize an ongoing criminal investigation and
“permit dissemination of a vast swath of materials.” Each of the government’s arguments lack
merit.
The Civil Litigation i:
First, the government claims the civil action is Resp. at 1. The assertion is
fivo10US.
' Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while
providing the unredacted version to the government and the Court. This reply describes and discusses
sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also
simultaneously files under separate cover her proposed redactions to her Request to Modify Protective
Order (Aug. 17, 2020), and this Reply, in accordance with the Court’s Order of August 18, 2020 (Doc.
44).
DOJ-OGR-00001763