Document EFTA 02829567¶
HADDON N¶
August 17, 2020¶
VIA ECF¶
The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007¶
Haddon, and MI P.0 Jeffrey Pagliuca¶
150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmtlaw.corn jpog6uco4hmtlaw.com¶
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 re uest rmission to exceed the three-page limitation and submit contemporaneously to 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)¶