Case 1:20-cr-00330-AJN Document 43 Filed 08/17/20 Page 1 of 1
iy Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
HADDON
MORGAN 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 ECF
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New York, NY 10007
Re: Request for Permission to Submit Letter Motion in Excess of Three Pages
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Pursuant to your Revised Individual Practices in Criminal Cases, specifically Practice 2.B, we
request permission to exceed the three-page limitation and submit contemporaneously to
chambers the letter motion (“motion,”) under seal, which is eight pages, exclusive of the
attachments. We felt that a substantial amount of background and factual information was
necessary to place the relief requested in the motion into context. Counsel for Ms. Maxwell spent
considerable time editing the motion to eliminate extraneous information and present the motion
as succinctly as possible.
Respectfully Submitted,
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00001729