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EFTA00027753.pdf

This document is a letter from the U.S. Attorney's Office to Judge Alison Nathan regarding the delivery of legal mail to Ghislaine Maxwell at the Metropolitan Detention Center (MDC). The Government explains the MDC's mail processing protocols and attributes a specific delay in delivering a hard drive to an 'institutional emergency' on October 13, 2021. Judge Nathan appends an order to the end of the document, denying the defense's request for a specific delivery order but stating a firm expectation that legal mail be delivered within one business day.

Legal correspondence / court order
2025-12-25

EFTA00018236.pdf

This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan in the case against Ghislaine Maxwell, dated April 5, 2021. The Government objects to the defense's use of Rule 17(c) subpoenas, specifically one directed at law firm Boies Schiller Flexner LLP (BSF) seeking a victim's original diary, characterizing it as an improper 'fishing expedition' for discovery. The Government requests that the Court require the defense to provide notice of all future subpoenas and to share any materials obtained with the prosecution.

Legal correspondence / letter motion
2025-12-25

EFTA00014697.pdf

A letter from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan dated November 22, 2021. The government requests permission to file a reply brief supporting their motion to prevent Dr. Ryan Hall from testifying in the case against Ghislaine Maxwell, citing issues regarding hearsay exceptions and relevance.

Legal correspondence / letter motion
2025-12-25

EFTA00011157.pdf

A letter from the U.S. Attorney's Office to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell, dated October 15, 2021. The Government argues against the defense's proposed November 15 deadline for filing motions under Federal Rule of Evidence 412 (regarding victim sexual behavior), requesting an earlier deadline to allow for proper hearings before trial. The document includes a handwritten order by Judge Nathan setting the motion deadline for October 27, 2021, with a tentative hearing on November 5, 2021.

Legal letter/court filing
2025-12-25

EFTA00010196.pdf

This document is a joint letter from the prosecution and defense to Judge Alison J. Nathan regarding Ghislaine Maxwell's confinement conditions at the MDC. The Government argues that a written response from MDC legal counsel is sufficient to address concerns, while the Defense argues that Warden Heriberto Tellez should appear in person to explain 'onerous' conditions such as 15-minute flashlight checks and body scans. Judge Nathan added a handwritten order at the end requiring MDC legal counsel to submit a letter by December 4, 2020, before determining if further action is needed.

Legal correspondence / court order
2025-12-25

DOJ-OGR-00015054.jpg

This is a legal letter dated July 22, 2025, from defense attorneys David Oscar Markus and Melissa Madrigal to Judge Paul A. Engelmayer regarding the case United States v. Ghislaine Maxwell. The defense requests permission to review grand jury transcripts that the government is seeking to unseal, noting that they have not previously seen them in their entirety. The letter states that Deputy Attorney General Todd Blanche has no objection to this request.

Legal letter / court filing
2025-11-20

DOJ-OGR-00008444.jpg

This is a legal filing from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated December 19, 2021. The letter concerns the ongoing trial of Ghislaine Maxwell and states that the prosecution ("The Government") and Maxwell's defense team have mutually agreed to allow a specific list of government exhibits, which were admitted during the trial, to be released to the public.

Legal document
2025-11-20

DOJ-OGR-00008436.jpg

This legal document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 19, 2021, concerning the case of United States v. Ghislaine Maxwell. The Government identifies a significant ambiguity in Jury Instruction No. 19, where the pronoun "she" could be interpreted as referring to either the defendant or the victim. To resolve this, the Government proposes that the court replace "she" with "the individual" to ensure clarity for the jury.

Legal document
2025-11-20

DOJ-OGR-00008357.jpg

This legal document is a letter dated December 12, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests that the court order the defense in the Ghislaine Maxwell case to provide a list of their witnesses for the upcoming week by 10:00 a.m. the next day. The letter also notes that the defense recently made an untimely production of other materials, and the Government intends to file a motion to preclude them.

Legal document
2025-11-20

DOJ-OGR-00008355.jpg

This legal document is a letter dated December 9, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter is a filing in the criminal case of United States v. Ghislaine Maxwell. It presents a jointly proposed limiting instruction for the jury regarding Government Exhibit 52, specifying that the exhibit is only to be considered for showing a potential link between Maxwell and listed contacts, not for the truth of the information itself.

Legal document
2025-11-20

DOJ-OGR-00008223.jpg

This is a letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the case against Ghislaine Maxwell, dated December 5, 2021. The prosecution outlines its plan to question 'Witness-3' about sexual activity with Epstein, adhering to the court's order to avoid explicit details. The government expresses concern that this limited questioning could be misinterpreted by the jury as a lack of witness credibility, especially in light of the defense's opening argument.

Legal document
2025-11-20

DOJ-OGR-00001862.jpg

This is a letter dated November 25, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan. The attorneys state their intention to file a renewed motion for bail for Ms. Maxwell and request an 'in camera' conference to discuss filing portions of the motion and supporting materials under seal. They argue for sealing to protect sensitive and private information concerning Ms. Maxwell and the third-party sureties (family and friends) supporting her bail application.

Legal document
2025-11-20

DOJ-OGR-00001832.jpg

This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated October 6, 2020, regarding the case against Ghislaine Maxwell. The prosecution requests permission to delay the disclosure of sensitive evidence, specifically photographs and documents related to victims of Jeffrey Epstein, to the defense until eight weeks before trial. The government argues this delay is necessary to protect an ongoing investigation and prevent the premature release of sensitive victim information, citing Federal Rule of Criminal Procedure 16(d)(1) as legal justification.

Legal document
2025-11-20

DOJ-OGR-00001741.jpg

This document is a letter motion dated August 24, 2020, from attorney Laura A. Menninger to Judge Alison J. Nathan of the Southern District of New York. The attorney requests permission to file documents under seal on behalf of her client, Ghislaine Maxwell, in the case of United States v. Ghislaine Maxwell. The justification for the request is that the documents contain information designated as confidential by the Government under the terms of the existing Protective Order in the case.

Legal document
2025-11-20

DOJ-OGR-00001737.jpg

This is a legal letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated August 21, 2020, concerning the case against Ghislaine Maxwell. The government requests permission to file the defendant's recent letter with redactions and to file all associated exhibits under seal. The justification for this request is an ongoing grand jury investigation, with the government citing the need to protect confidential materials.

Legal document
2025-11-20

DOJ-OGR-00001719.jpg

This legal document is a letter dated August 13, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution is opposing recent requests from the defendant, Ghislaine Maxwell, for an early disclosure of government witnesses and for the court to intervene with the Bureau of Prisons. The government argues these requests are premature and meritless, citing the early stage of discovery and previous denials of similar applications by the court.

Legal document
2025-11-20

DOJ-OGR-00001713.jpg

This is a letter motion dated August 10, 2020, from Ghislaine Maxwell's defense attorneys (Cohen & Gresser LLP) to Judge Alison J. Nathan. The defense is requesting two court orders: one to compel the government to disclose the identities of 'Victims 1-3' mentioned in the indictment, and another to direct the Bureau of Prisons to move Maxwell to the general population to facilitate access to discovery materials. The document includes a handwritten and stamped order from Judge Nathan dated August 11, 2020, setting a deadline of August 13 for the government's response.

Legal correspondence / court order
2025-11-20

DOJ-OGR-00001662.jpg

This legal document is a letter dated July 27, 2020, from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests an opportunity to respond to a motion for a protective order filed that morning by the defense counsel for Ghislaine Maxwell. The letter notes that the defense's filing was a surprise, as the Government believed discussions to jointly propose a protective order were still ongoing.

Legal document
2025-11-20

DOJ-OGR-00001538.jpg

This legal document is a letter dated July 7, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the criminal case against Ghislaine Maxwell. The prosecution proposes a briefing schedule for Maxwell's detention hearing following her arrest on July 2, 2020, and renews its request to exclude time under the Speedy Trial Act. The letter confirms the parties are available for a remote hearing on July 14, 2020.

Legal document
2025-11-20

DOJ-OGR-00001536.jpg

This document is a letter dated July 6, 2020, from attorneys Mark S. Cohen and Christian R. Everdell (Cohen & Gresser LLP) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense informs the court that they finally made contact with Maxwell at the Metropolitan Detention Center that evening and she has waived her physical presence for upcoming proceedings. The defense and prosecution have agreed to schedule the remote arraignment and bail hearing for the morning of July 14, 2020.

Legal correspondence / court filing
2025-11-20

DOJ-OGR-00001435.jpg

This document is a status letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan, dated May 5, 2021, regarding the case United States v. Ghislaine Maxwell. It details the protocols for flashlight security checks at the Metropolitan Detention Center (MDC), explaining that checks are generally conducted every 30 minutes in the SHU and hourly in the general population. However, the letter specifies that Ghislaine Maxwell is subject to checks every 15 minutes because she is on an 'enhanced security schedule,' though not on suicide watch.

Legal correspondence / government letter to court
2025-11-20

DOJ-OGR-00001357.jpg

This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated February 4, 2021. The letter provides an update on the conditions of confinement for the defendant, Ghislaine Maxwell, at the Metropolitan Detention Center (MDC). The Government reports that Maxwell has more time to review discovery materials than any other inmate (13 hours daily via computer) and has regular, private communication with her attorneys through video and phone calls, despite the suspension of in-person visits due to COVID-19.

Legal document
2025-11-20

DOJ-OGR-00001343.jpg

This letter, dated November 23, 2020, is from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. It provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC). The letter details that Maxwell was placed in quarantine after a potential COVID-19 exposure from a staff member, outlines the quarantine protocols, and confirms that she has been provided with a laptop to review discovery materials and can still make private legal calls.

Letter
2025-11-20

DOJ-OGR-00001179.jpg

This legal document, a letter dated December 15, 2020, from Boies Schiller Flexner LLP, contains a statement from Annie Farmer opposing Ghislaine Maxwell's renewed motion for bail. Farmer, a victim of Maxwell, details Maxwell's history of abuse, manipulative behavior, and flight risk, arguing that Maxwell is a psychopath who lacks remorse and would flee to avoid justice. The statement emphasizes the need for Maxwell to stand trial to ensure justice for her victims.

Legal document
2025-11-20

DOJ-OGR-00020596.jpg

This document is a letter dated July 28, 2022, from an appellate counsel at the law firm Aidala, Bertuna & Kamins, P.C. to the Clerk of Court. The lawyer, newly assigned to Ghislaine Maxwell's appeal, requests an extension to file the Appellant's Brief, moving the deadline from October 14, 2022, to January 30, 2023. The justification for the request includes the voluminous nature of the case record (over 3,800 pages of transcripts and 738 docket entries) and the fact that the lawyer has been unable to meet with Maxwell following her recent transfer to a prison in Tallahassee, Florida.

Legal document
2025-11-20
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