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417 KB

Extraction Summary

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

Document Information

Type: Legal filing / appellate brief (conclusion page)
File Size: 417 KB
Summary

This is the conclusion page of a legal filing (Case 20-3061) dated October 8, 2020, arguing on behalf of Ghislaine Maxwell. The text requests that the appellate court reverse a district court order denying Maxwell's motion to modify a protective order. It references the 'Martindell' legal standard and accuses the government of trying to shield itself from a forthcoming motion before Judge Nathan.

People (3)

Name Role Context
Ms. Maxwell Defendant/Appellant
Subject of the motion to modify a protective order; challenging government circumvention.
Judge Nathan Judge
Judge presiding over a related matter where Maxwell has a forthcoming motion.
Judge Preska Judge
District court judge; the filing argues she should not 'remain in the dark'.

Organizations (3)

Name Type Context
The government
Opposing Maxwell's motion; accused of trying to shield itself.
This Court
The court being addressed to reverse the lower court's order (likely 2nd Circuit Court of Appeals based on Case 20-30...
District court
The court that issued the order denying Maxwell's motion.

Timeline (2 events)

2020-10-08
Filing of legal document concluding arguments to reverse district court order.
Court of Appeals
Unknown (Future relative to doc)
Ms. Maxwell's forthcoming motion before Judge Nathan.
Court

Relationships (2)

Ms. Maxwell Adversarial/Legal The government
Maxwell is challenging the government's circumvention of Martindell.
Ms. Maxwell Legal/Judicial Judge Nathan
Maxwell has a forthcoming motion before Judge Nathan.

Key Quotes (4)

"The government wants to shield itself from Ms. Maxwell’s forthcoming motion before Judge Nathan challenging its circumvention of Martindell."
Source
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Quote #1
"This Court should not prejudge the Martindell issue as the government seeks."
Source
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Quote #2
"At bottom, when asked to justify why Judge Preska and this Court should remain in the dark, the government offers little more than this: because the protective order says so."
Source
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Quote #3
"This Court should reverse the district court’s order denying Ms. Maxwell’s motion to modify the protective order."
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (805 characters)

Case 20-3061, Document 94, 10/08/2020, 2948481, Page21 of 23
though, is obvious: The government wants to shield itself from Ms. Maxwell’s
forthcoming motion before Judge Nathan challenging its circumvention of
Martindell. This Court should not prejudge the Martindell issue as the government
seeks.
Conclusion
At bottom, when asked to justify why Judge Preska and this Court should
remain in the dark, the government offers little more than this: because the
protective order says so. But in the face of all the reasons why the relevant judicial
decision makers should have all the relevant information, the government’s answer
is not good enough.
This Court should reverse the district court’s order denying Ms. Maxwell’s
motion to modify the protective order.
October 8, 2020.
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DOJ-OGR-00019667

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