DOJ-OGR-00020541.jpg

Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page55 of 92

(Entered: 11/02/2021)

11/02/2021
405
JOINT LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J.
Nathan from AUSAs Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
November 2, 2021 re: Trial length Document filed by USA. (Rohrbach, Andrew)
(Entered: 11/02/2021)

11/02/2021
406
JOINT LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Jeffrey S. Pagliuca dated November 2, 2021 re: Fed. R. Evid. 412 and 702 Motions
Hearing Date (Pagliuca, Jeffrey) (Entered: 11/02/2021)

11/03/2021
407
MOTION for Reconsideration Re: Disclosure of Juror Names to Counsel Only upon
completion of Questionnaire. Document filed by Ghislaine Maxwell. (Sternheim,
Bobbi) (Entered: 11/03/2021)

11/03/2021
408
MOTION for Reconsideration re: Release on Bond. Document filed by Ghislaine
Maxwell. (Sternheim, Bobbi) (Entered: 11/03/2021)

11/03/2021
409
ORDER as to Ghislaine Maxwell. The Court is in receipt of the parties' joint letter in
response to this Court's order dated October 31, 2021. Dkt. No. 406. The Court will
hold a hearing on November 10, 2021 at 9:00 a.m. on the Defendant's motion under
Federal Rule of Evidence 412, Dkt. No. 378, the Defendant's motion in limine to
exclude under Federal Rule of Evidence 702 and Daubert v. Merrell Dow
Pharmaceuticals, Inc., 509 U.S. 579 (1993), Dkt. No. 386, and the other outstanding
issues that overlap with these two motions as discussed at the November 1, 2021
conference. The proceeding will take place in Courtroom 110 of the United States
District Court for the Southern District of New York, Thurgood Marshall U.S.
Courthouse at 40 Foley Square, New York, New York. The Court will provide
information on public access (for the portion of the Daubert hearing that does not
overlap with the Rule 412 issues) as soon as it is available. Otherwise, the Court will
order the following briefing schedule if the Government seeks to exclude any of the
Defendant's anticipated witness testimony as disclosed in her November 1, 2021
notice. See Dkt. No. 406: Government brief to be filed on ECF: November 8, 2021;
Defense response brief to be filed on ECF: November 11, 2021. The parties are further
ORDERED to docket Exhibit A to Dkt. No. 406 with any proposed redactions on or
before November 8, 2021. In order to facilitate the Court's review of any proposed
redactions, the parties must also submit via email a highlighted copy. SO ORDERED.
( Status Conference set for 11/10/2021 at 09:00 AM in Courtroom 110, 40 Centre
Street, New York, NY 10007 before Judge Alison J. Nathan. ) (Signed by Judge
Alison J. Nathan on 11/3/2021)(bw) (Entered: 11/03/2021)

11/03/2021
412
ORDER as to Ghislaine Maxwell. The Court is in receipt of the Government's letter
dated November 2, 2021. Dkt. No. 403. The Government is hereby ORDERED to
confer further with MDC legal counsel and file a letter regarding Defendant's
transportation to the courthouse for proceedings in this matter on or before November
8, 2021. The Court hereby authorizes the letter to be filed under seal because such
information may implicate security concerns. The Court will also confer with the
United States Marshal for the Southern District of New York and with the District
Executive regarding transportation of the Defendant for upcoming in court
proceedings and trial. With respect to legal mail, the Court requires MDC Legal
Counsel to consider what additional steps can be taken (including what steps by
counsel for the Government or the Defendant) to ensure that within the weeks leading
up to trial, Ms. Maxwell promptly receives her legal mail. The Government shall
docket a letter with MDC Legal Counsel's proposal on or before November 8, 2021.
The Court will also transmit this Order to Chief Judge Brodie, who is overseeing the
litigation and mediation in Case No. 19-cv-660 (E.D.N.Y.) regarding access to
counsel for pre-trial detainees being held at the MDC so that the issue can be
discussed as to all MDC pre-trial detainees who require prompt access to legal mail in
the weeks leading up to their trials. SO ORDERED. (Signed by Judge Alison J. Nathan
on 11/3/2021)(bw) (Entered: 11/04/2021)

11/03/2021
Transmission to Sealed Records Clerk: as to Ghislaine Maxwell. Transmitted re: 412
Order, to the Sealed Records Clerk for the sealing of document. (bw) (Entered:
11/04/2021)

DOJ-OGR-00020541