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670 KB
Extraction Summary
4
People
3
Organizations
2
Locations
0
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing
File Size:
670 KB
Summary
A legal letter dated October 14, 2020, from Ghislaine Maxwell's attorney, Christian R. Everdell, to Judge Alison J. Nathan. The defense opposes the government's request to delay the disclosure of evidence (photographs and documents) related to alleged victims of Jeffrey Epstein. The defense argues that these materials are exculpatory under Brady v. Maryland because the witnesses allege abuse by Epstein but do not accuse Maxwell of participation.
People (4)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Attorney |
Author of the letter, representing Ghislaine Maxwell, partner at Cohen & Gresser LLP.
|
| Alison J. Nathan | Judge |
Recipient of the letter, presiding over the United States District Court, Southern District of New York.
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| Ghislaine Maxwell | Defendant |
Client of Christian R. Everdell, subject of the criminal case 20 Cr. 330.
|
| Jeffrey Epstein | Alleged Abuser |
Mentioned regarding alleged victims of sexual abuse; defense argues materials related to him are exculpatory for Maxw...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Cohen & Gresser LLP |
Law firm representing Ghislaine Maxwell.
|
|
| United States District Court, Southern District of New York |
Court where the case is being heard.
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| The Government |
Prosecution/DOJ, opposing party in the case.
|
Locations (2)
| Location | Context |
|---|---|
|
Address of Cohen & Gresser LLP.
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|
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Address of the United States Courthouse.
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Relationships (2)
Letter states 'We write on behalf of our client, Ghislaine Maxwell'
Letter discusses witnesses alleging abuse by Epstein but notes they have 'not accused Ms. Maxwell of participating in or facilitating that conduct'
Key Quotes (4)
"We write on behalf of our client, Ghislaine Maxwell, in opposition to the government’s October 6, 2020 letter requesting the Court’s permission to delay the disclosure of photographs and documents relating to certain alleged victims of sexual abuse by Jeffrey Epstein"Source
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Quote #1
"Materials pertain to individuals who claim to have been 'sexually abused by [Jeffrey] Epstein' ... but who have not accused Ms. Maxwell of participating in or facilitating that conduct in any way."Source
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Quote #2
"Accordingly, the Materials identifying these witnesses and their prior statements are exculpatory evidence, which must be disclosed pursuant to the government’s obligations under Brady v. Maryland"Source
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Quote #3
"The Court should order the government to disclose the Materials under Rule 16 because the Materials are 'material to preparing the defense'"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,100 characters)
Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 1 of 6
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
C&G COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
+1 (212) 957-7600
ceverdell@cohengresser.com
October 14, 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, NY 10007
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write on behalf of our client, Ghislaine Maxwell, in opposition to the government’s October 6, 2020 letter requesting the Court’s permission to delay the disclosure of photographs and documents relating to certain alleged victims of sexual abuse by Jeffrey Epstein (the “Materials”), pursuant to Rule 16(d)(1) of the Federal Rules of Criminal Procedure. (Dkt. 60). The government’s request should be denied for two reasons.
First, it is clear from the government’s letter that the Materials pertain to individuals who claim to have been “sexually abused by [Jeffrey] Epstein” (id. at 2), but who have not accused Ms. Maxwell of participating in or facilitating that conduct in any way. Accordingly, the Materials identifying these witnesses and their prior statements are exculpatory evidence, which must be disclosed pursuant to the government’s obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny.1
Second, the Court should order the government to disclose the Materials under Rule 16 because the Materials are “material to preparing the defense” and the government has not shown good cause to delay production of the Materials under Rule 16(d)(1).
__________________________________________________________________
1 We note that yesterday we sent the government a letter making specific Brady requests, including “[a]ny statements or written communications made by any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein, but has not alleged that Ms. Maxwell participated in, was involved in, or facilitated the alleged sexual abuse.”
1 We note that yesterday we sent the government a letter making specific Brady requests, including “[a]ny statements or written communications made by any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein, but has not alleged that Ms. Maxwell participated in, was involved in, or facilitated the alleged sexual abuse.”
DOJ-OGR-00001795
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