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587 KB

Extraction Summary

3
People
3
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing (appellate brief)
File Size: 587 KB
Summary

This document is a page from a legal brief filed on September 24, 2020, in Case 20-3061 (Giuffre v. Maxwell). It argues that Ghislaine Maxwell is being treated unfairly because she is barred from sharing information sealed under a criminal protective order with judicial officers in her civil unsealing proceedings (presided over by Judge Preska). The brief asserts that the district court erred and abused its discretion by declining to modify the protective order under Federal Rule of Criminal Procedure 16(d)(1).

People (3)

Name Role Context
Ghislaine Maxwell Defendant/Appellant
Seeking to introduce criminal protective order-sealed information; arguing unfairness in current proceedings.
Loretta Preska Judge
Presiding over the unseal decisions in the Giuffre v. Maxwell case.
Virginia Giuffre Plaintiff (implied by case name)
Named in the case title 'Giuffre v. Maxwell'.

Organizations (3)

Name Type Context
Department of Justice
Inferred from Bates stamp 'DOJ-OGR' (Office of Government Relations).
United States Supreme Court
Referenced in case citation 'Koon v. United States'.
District Court
Referenced as the court that allegedly erred in declining to modify the protective order.

Timeline (2 events)

2020-09-24
Filing of Document 60 in Case 20-3061
Appellate Court (implied by Case 20-3061)
N/A
Giuffre v. Maxwell unseal proceedings
District Court

Relationships (2)

Ghislaine Maxwell Legal Adversaries Virginia Giuffre
Case title 'Giuffre v. Maxwell'
Ghislaine Maxwell Defendant/Judge Loretta Preska
Reference to 'Judge Preska’s unseal decisions' regarding Maxwell.

Key Quotes (4)

"This situation is fundamentally unfair to Ms. Maxwell."
Source
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Quote #1
"There is no reason all judicial officers presiding over any case implicating Ms. Maxwell’s interests should not have access... to all relevant information"
Source
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Quote #2
"A district court by definition abuses its discretion when it makes an error of law."
Source
DOJ-OGR-00019430.jpg
Quote #3
"The district court erred in declining to modify the protective order."
Source
DOJ-OGR-00019430.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,325 characters)

Case 20-3061, Document 60, 09/24/2020, 2938278, Page31 of 58
Giuffre v. Maxwell unseal proceedings, into which Ms. Maxwell seeks to introduce
criminal protective order-sealed information relevant to Judge Preska’s unseal
decisions.
This situation is fundamentally unfair to Ms. Maxwell. There is no reason all
judicial officers presiding over any case implicating Ms. Maxwell’s interests should
not have access, whether under seal, in camera, or otherwise, to all relevant
information, and there is no reason Ms. Maxwell should be barred from providing
such relevant information to them.
A. Preservation and standard of review.
Ms. Maxwell preserved this issue for appeal. App. 124–31, 293–98.
This Court reviews for an abuse of discretion an order denying a motion to
modify a protective order. Martindell, 594 F.2d at 295. A district court by definition
abuses its discretion when it makes an error of law. Koon v. United States, 518 U.S.
81, 100 (1996).
B. The district court erred in declining to modify the protective order.
Federal Rule of Criminal Procedure 16(d)(1) authorizes district courts to
enter or modify protective orders for good cause. Fed. R. Crim. P. 16(d)(1). In this
case, several reasons exist for the narrow modification of the criminal protective
order Ms. Maxwell proposes.
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