EFTA00027701.pdf

56.1 KB

Extraction Summary

6
People
2
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Email thread
File Size: 56.1 KB
Summary

This document is an internal email thread among Assistant United States Attorneys for the Southern District of New York (SDNY) dated October 18, 2021, regarding the Ghislaine Maxwell trial. The prosecutors discuss revisions to Motions in Limine (MILs) and letters to Judge Nathan, specifically strategizing on how to address a witness's prior limited media comments about Epstein versus their expected court testimony, and the need to seal claims of 'Maxwell abuse' to prevent tainting the jury pool.

People (6)

Name Role Context
Judge Nathan Judge
Mentioned in relation to a 'key' letter and reviewing articles regarding witness comments.
Jeffrey Epstein Deceased financier / Sex Offender
Mentioned in the context of a witness having made limited comments about him in articles compared to expected court t...
Ghislaine Maxwell Defendant
Mentioned as 'Maxwell'; discussion regarding claims of 'Maxwell abuse' and potential prejudicial publicity.
[Redacted] Witness/Victim
A person whose previous media comments about Epstein are being compared to their expected testimony.
[Redacted] Assistant United States Attorney
Sender of the original email with attachments.
[Redacted] USANYS Staff
Various senders and recipients discussing the legal filings.

Organizations (2)

Name Type Context
USANYS
United States Attorney's Office for the Southern District of New York (SDNY), the organization the email participants...
Southern District of New York
Jurisdiction mentioned in signature block.

Timeline (1 events)

2021-10-18
Internal SDNY discussion regarding Motions in Limine (MILs) and letters to Judge Nathan for the Ghislaine Maxwell trial.
New York
USANYS Attorneys

Locations (1)

Location Context
Address in email signature.

Relationships (2)

Ghislaine Maxwell Co-conspirators/Associates Jeffrey Epstein
Document discusses trial filings (MILs) related to Maxwell, mentioning comments made about Epstein.
Judge Nathan Judicial Oversight USANYS
USANYS attorneys discussing letters and motions to be sent to Judge Nathan.

Key Quotes (3)

"would it be possible to include a sentence on [Redacted] pointing to Judge Nathan to whatever the article(s) in which she has made comments about Epstein that are far more limited than what she will say in court?"
Source
EFTA00027701.pdf
Quote #1
"I think we should add a sentence explaining why we think the claim of Maxwell abuse will cause prejudicial publicity."
Source
EFTA00027701.pdf
Quote #2
"Namely, to air that issue in a public filing when there may well be no good faith basis for it would potentially taint the jury pool."
Source
EFTA00027701.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,793 characters)

From: [REDACTED] (USANYS)" <[REDACTED]>
To: [REDACTED] (USANYS)" <[REDACTED]>
Subject: RE: Revised MILs and letters
Date: Mon, 18 Oct 2021 20:36:02 +0000
OK will do.
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Monday, October 18, 2021 4:35 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Subject: RE: Revised MILs and letters
Go ahead — I’m not in them. I didn’t have comments. And agree with the below.
From: [REDACTED] (USANYS) <[REDACTED]>
Sent: Monday, October 18, 2021 4:34 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Subject: RE: Revised MILs and letters
Here are a few comments on the motion. I looked at the two letters also, and have one suggestion on each (I’m happy to propose language in redline, but you may be in the docs)
1. On the “key” letter — would it be possible to include a sentence on [REDACTED] pointing to Judge Nathan to whatever the article(s) in which she has made comments about Epstein that are far more limited than what she will say in court?
2. On the sealing letter — I think we should add a sentence explaining why we think the claim of Maxwell abuse will cause prejudicial publicity. Namely, to air that issue in a public filing when there may well be no good faith basis for it would potentially taint the jury pool.
From: [REDACTED] <[REDACTED]>
Sent: Monday, October 18, 2021 3:46 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Subject: Revised MILs and letters
Hi [REDACTED] and [REDACTED]
Attached for your review are:
1. Revised MILs
2. A redline
3. A draft cover letter
4. A draft index letter with victim information
Thanks!
[REDACTED]
Assistant United States Attorney
Southern District of New York
New York, New York 10007
[REDACTED]
EFTA00027701
EFTA00027702

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