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Case 1:20-cr-00330-AJN Document 67 Filed 10/30/20 Page 1 of 4
U.S. Department of Justice

United States Attorney
Southern District of New York

The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

October 30, 2020

BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)

Dear Judge Nathan:

The Government respectfully submits this letter in response to the defense letter dated October 23, 2020 in the above-referenced case (the “Defense Letter”). For all of its innuendo and accusations, the Defense Letter is at base an effort to preview again motions that the Court has already found to be premature, and to cast the Government’s efforts to be transparent with the Court and the defense in a nefarious and deeply misleading light. The Government writes to correct the inaccuracies in the Defense Letter, to update the Court regarding the status of the Government’s ongoing discovery productions, and to address the defense complaints regarding the Metropolitan Detention Center (“MDC”).

1. The Government Has and Will Continue to Satisfy Its Discovery Obligations

The Defense Letter raises numerous accusations, including that the Government has “abandon[ed]” the discovery deadlines in this case. (Def. Ltr. 1). The Government strongly disagrees, and notes that it has produced considerable Rule 16 discovery to the defense, which, to date, consists of more than 350,000 pages. Contrary to the defense’s assertions, that discovery does include both “[c]orroborating [i]nformation” regarding the conduct charged in this case as well as potentially “[e]xculpatory [e]vidence,” (Def. Ltr. 3), and the Government remains available to discuss that material with defense counsel. Moreover, in anticipation of the November 9, 2020 discovery deadline, the Government is preparing to make additional productions, including a production of electronic discovery, which will consist of over 1.2 million documents from devices seized from Jeffrey Epstein’s residences.1 In that regard, the Government is currently waiting on

1 Despite the defense’s insinuations to the contrary, this is entirely consistent with the schedule ordered by the Court. Specifically, the Court ordered the Government to produce “[i]nitial non-electronic discovery, generally to include search warrant applications and subpoena returns” by August 21, 2020, and the Government made three productions containing those materials, and more, by August 21, 2020. (Order dated July 15, 2020, Dkt. No. 25). It is the Government’s expectation that its upcoming productions will substantially complete its production of Rule 16 discovery. As is not uncommon in a case of this magnitude, however, it is possible that the

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