DOJ-OGR-00008364.jpg
581 KB
Extraction Summary
6
People
4
Organizations
2
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
581 KB
Summary
A letter dated December 13, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter informs the court of the defense's intention to question attorneys Jack Scarola, Brad Edwards, and Robert Glassman and argues that these questions do not violate attorney-client privilege. The document cites legal precedents regarding the burden of proof for privilege claims.
People (6)
| Name | Role | Context |
|---|---|---|
| Jeffrey S. Pagliuca | Attorney |
Author of the letter, representing Ghislaine Maxwell, from the firm Haddon, Morgan and Foreman, P.C.
|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding Judge of the United States District Court, Southern District of New York.
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell); the defense anticipates asking questions of specific witnes...
|
| Jack Scarola | Attorney/Witness |
Attorney whom Ms. Maxwell anticipates questioning.
|
| Brad Edwards | Attorney/Witness |
Attorney whom Ms. Maxwell anticipates questioning.
|
| Robert Glassman | Attorney/Witness |
Attorney whom Ms. Maxwell anticipates questioning.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Haddon, Morgan and Foreman, P.C |
Defense law firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
Court where the case is being heard.
|
|
| United States Government |
Prosecution (Plaintiff) in the case.
|
|
| Second Circuit Court of Appeals |
Referenced in legal citations (2d Cir.).
|
Timeline (2 events)
2021-12-14
Document filed with the court (Document 544).
Southern District of New York
Future (Anticipated)
Questioning of Attorneys Jack Scarola, Brad Edwards, and Robert Glassman by the defense.
Court
Locations (2)
| Location | Context |
|---|---|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of the United States District Court.
|
Relationships (3)
Pagliuca is writing on behalf of Maxwell's defense.
Maxwell anticipates asking questions of Scarola.
Maxwell anticipates asking questions of Edwards.
Key Quotes (3)
"I write to alert the Court to the questions Ms. Maxwell anticipates asking Attorneys Jack Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will offer are protected by the attorney client privilege."Source
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Quote #1
"None of the questions Ms. Maxwell intends to ask these witnesses implicates the attorney-client privilege."Source
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Quote #2
"Rather, all the questions concern interactions between the"Source
DOJ-OGR-00008364.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,614 characters)
Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 1 of 9
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
HADDON
MORGAN
FOREMAN
MORGAN
FOREMAN
December 13, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write to alert the Court to the questions Ms. Maxwell anticipates asking Attorneys Jack
Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will
offer are protected by the attorney client privilege.
Scarola, Brad Edwards, and Robert Glassman, and to explain why none of the answers they will
offer are protected by the attorney client privilege.
"The attorney-client privilege protects from disclosure (1) a communication between
client and counsel that (2) was intended to be and was in fact kept confidential, and (3) was made
for the purpose of obtaining or providing legal advice." In re County of Erie, 473 F.3d 413, 419
(2d Cir. 2007). "The burden of establishing the attorney-client privilege, in all its elements,
always rests upon the person asserting it." United States v. Schwimmer, 892 F.2d 237, 244 (2d
Cir. 1989). The burden here falls on the government.
client and counsel that (2) was intended to be and was in fact kept confidential, and (3) was made
for the purpose of obtaining or providing legal advice." In re County of Erie, 473 F.3d 413, 419
(2d Cir. 2007). "The burden of establishing the attorney-client privilege, in all its elements,
always rests upon the person asserting it." United States v. Schwimmer, 892 F.2d 237, 244 (2d
Cir. 1989). The burden here falls on the government.
None of the questions Ms. Maxwell intends to ask these witnesses implicates the
attorney-client privilege. Indeed, none calls for an attorney to reveal confidential
communications with his client at all, let alone a communication made for the purpose of
obtaining or providing legal advice. Rather, all the questions concern interactions between the
attorney-client privilege. Indeed, none calls for an attorney to reveal confidential
communications with his client at all, let alone a communication made for the purpose of
obtaining or providing legal advice. Rather, all the questions concern interactions between the
DOJ-OGR-00008364
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