This document is a legal reply filed by Jeffrey Pagliuca on behalf of Ghislaine Maxwell, addressing the request to modify a protective order in the case United States v. Ghislaine Maxwell. The reply argues against the government's position on the disclosure of materials from a civil litigation case that are also part of the criminal discovery. It challenges the government's claims about the unrelated nature of the civil litigation, the standard practice of issuing subpoenas, and the confidentiality of the investigation. The document seeks permission to disclose certain sealed materials to the Second Circuit Court of Appeals and a separate district court, arguing that these materials are crucial for the related civil litigation and the criminal case.
documents/EFTA00088205.pdf
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