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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 1, 2021, regarding the case against Ghislaine Maxwell. The government responds to Maxwell's request for expanded laptop access to review discovery materials on weekends, stating it has no objection but ultimately defers to the Metropolitan Detention Center's (MDC) policies. The letter details the extensive access Maxwell has already been granted, including a dedicated laptop and desktop computer, arguing she has ample opportunity to review the evidence.
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This is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Dated January 28, 2021, the letter responds to a court order about proposed redactions to the defendant's pre-trial motions. The Government states its agreement with the proposed redactions, arguing they are necessary to protect the integrity of an ongoing investigation, maintain grand jury secrecy, and protect the privacy of victim-witnesses.
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A legal letter dated January 25, 2021, from the law firm Cohen & Gresser LLP to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter lists 12 specific pretrial motions being filed by the defense, including motions to dismiss various counts of the indictment, suppress evidence, and separate trials. Two of the motions (items 3 and 11) contain redactions regarding the target of a government subpoena.
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This legal document is a letter dated December 18, 2020, from attorney Christian R. Everdell of Cohen & Gresser LLP to Judge Alison J. Nathan. The letter informs the court of the submission of two versions of a reply memorandum concerning their client Ghislaine Maxwell's renewed motion for bail. One version is unredacted and filed under seal, while the other is redacted for public viewing, citing privacy concerns and confidential financial information as reasons for the redactions.
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This is a legal letter dated December 18, 2020, from attorneys Christian R. Everdell and Mark S. Cohen of COHEN & GRESSER LLP to Judge Alison J. Nathan. The attorneys, representing their client Ghislaine Maxwell, are requesting to file documents related to her motion for bail under seal. They seek to submit an unredacted version for the court and a redacted version for the public, citing privacy concerns and the need to protect confidential information, including financial documents, as governed by a protective order.
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This document is a legal cover letter dated December 8, 2020, from attorneys Mark Cohen and Christian Everdell to Judge Alison Nathan regarding the case United States v. Ghislaine Maxwell. The attorneys are submitting a Renewed Motion for Bail under seal, providing both an unredacted version for the court and a redacted version for public filing to protect privacy and confidential financial information. The document references previous correspondence and protective orders governing discovery materials.
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This legal document is a letter dated November 23, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter provides an update on the confinement conditions of defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), specifically that she was placed in quarantine after a staff member tested positive for COVID-19. The letter details that Maxwell tested negative, outlines the protocols for her quarantine including access to legal calls and discovery materials, and confirms she is being monitored by medical staff.
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This legal document is a letter dated October 6, 2020, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The prosecution requests permission to delay the disclosure of sensitive evidence—photographs and documents of Jeffrey Epstein's sexual abuse victims—to Ghislaine Maxwell's defense team until eight weeks before trial. The government argues this is necessary to protect an ongoing investigation and sensitive victim information, while noting the defense objects to this request.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to the Clerk of the Second Circuit Court of Appeals regarding the case of United States v. Ghislaine Maxwell. The letter cites the precedent set in United States v. Watkins to argue that the Bail Reform Act permits a court to conduct a fact-based, "conduct-specific inquiry" for felonies involving a minor victim, rather than being limited to the legal elements of the charge. This submission is intended to provide supplemental authority to the court concerning the upcoming argument in Maxwell's case.
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This legal document is a letter from the U.S. Attorney's Office for the Southern District of New York to the Clerk of the U.S. Court of Appeals for the Second Circuit. The letter, dated March 13, 2023, concerns the case of United States v. Ghislaine Maxwell, advising the court that the government intends to file its appeal brief by May 30, 2023, and also requests permission to file a supplemental appendix.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated June 22, 2022. The letter confirms that the government has complied with a court order by notifying the six victims in the Ghislaine Maxwell case (identified as Jane, Annie, Kate, Carolyn, Virginia, and Melissa) of their rights to be heard at the upcoming sentencing on June 28, 2022, as stipulated by the Crime Victims' Rights Act.
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This legal document is a letter dated June 26, 2022, from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan. The letter serves as a court filing in the case of United States v. Ghislaine Maxwell. In it, the government submits a motion filed by the attorney for an individual named 'Kate', which was attached to her victim impact statement, in response to a court order issued that same day.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated June 26, 2022, regarding the case of Ghislaine Maxwell. The prosecution states that, in response to a court order, they have confirmed with the Metropolitan Detention Center's Warden and Chief Psychologist that the defendant has full access to her legal documents and counsel. Consequently, the government argues there is no reason to postpone her sentencing.
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This document is a letter from Sigrid S. McCawley, counsel for Annie Farmer, to Judge Alison J. Nathan, dated June 22, 2022. It provides Annie Farmer's victim impact statement regarding the crimes committed by Ghislaine Maxwell and Jeffrey Epstein, and requests permission for Ms. Farmer to make an oral statement at Maxwell's sentencing. The statement details the profound and ongoing psychological and emotional impact of the abuse on Annie Farmer.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated June 24, 2022, regarding the case of United States v. Ghislaine Maxwell. The letter responds to a court order about the defendant's objections to victim statements, identifying six victims by their first names (Jane, Annie, Kate, Carolyn, Virginia, and Melissa). It also notes that two of the victims, Kate and Annie, plan to attend the upcoming sentencing hearing.
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A letter dated June 22, 2022, from attorney Sigrid S. McCawley to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. McCawley, representing Teresa Helm, asserts that Helm was trafficked by Maxwell in 2002 and requests permission for Helm to make an oral victim impact statement at the upcoming sentencing. The majority of the detailed statement is redacted.
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The U.S. Attorney for the Southern District of New York submitted a letter motion to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The motion, dated May 11, 2022, requests the exclusion of time under the Speedy Trial Act for two counts until Maxwell's scheduled sentencing on June 28, 2022. The government intends to dismiss these counts but seeks the exclusion as a precaution, noting that the defense counsel consents to the request, which was granted by the judge.
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This legal document is a letter from the law firm Boies Schiller Flexner LLP (BSF) to Judge Alison J. Nathan, dated March 22, 2021, regarding the case of United States v. Ghislaine Maxwell. BSF objects to a subpoena issued by Maxwell's defense, arguing it is overly broad and lacks clarity on which victims require notice, while clarifying that the firm represents victims Annie Farmer (Minor Victim-2) and Virginia Giuffre. The firm states its intention to notify all Epstein victims it represents about the subpoena out of an abundance of caution.
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This is a letter from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan, dated March 29, 2021, regarding the case of United States v. Ghislaine Maxwell. The government seeks to clarify a previous statement from October 2020 where it claimed no involvement by its prosecution team in an earlier 'Florida Investigation'. The letter now states that new information suggests the FBI's New York Office may have participated in that Florida investigation between 2005 and 2010, and the government is reviewing files to determine the extent of the interaction.
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This legal document is a letter dated March 29, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The letter serves to notify the court that a Grand Jury has returned a superseding indictment against the defendant, Ghislaine Maxwell. The Government outlines its intent to explain the differences between the new and prior indictments and address the impact on discovery and pending motions, while also stating it does not intend to seek further indictments if the trial proceeds as scheduled on July 12, 2021.
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This legal document is a letter dated March 26, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, who is presiding over the case against Ghislaine Maxwell. The prosecution informs the court of a recent ruling in a separate case, U.S. v. Schulte, where Judge Crotty denied a motion to dismiss the indictment that was 'virtually identical' to one filed by Maxwell. The government argues that this precedent supports their position that Maxwell's motion should also be denied.
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This is a legal letter dated March 26, 2021, from attorney Sigrid S. McCawley of Boies Schiller Flexner LLP to Judge Alison J. Nathan regarding the case *United States v. Ghislaine Maxwell*. The letter informs the court that BSF, representing victims, has conferred with the defendant's counsel and agreed to redact a small piece of information from a recent filing out of caution. BSF states it will remove these redactions if the court orders it to do so.
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A legal cover letter dated March 15, 2021, from attorneys Cohen and Everdell of Cohen & Gresser LLP to Judge Alison J. Nathan. The letter lists ten reply memoranda being filed on behalf of their client, Ghislaine Maxwell, in the case United States v. Ghislaine Maxwell. These filings relate to motions to dismiss indictments, suppress evidence (involving a redacted subpoena target), sever counts, and request a bill of particulars.
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This legal document is a letter dated October 12, 2021, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. In response to a court order, the government estimates its case-in-chief will last approximately four weeks. The letter also confirms that the government has provided the defense with its exhibit list, witness list, and other required materials.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan, dated April 5, 2021, concerning the case against Ghislaine Maxwell. The prosecution requests that the court compel Maxwell's defense to share a copy of a proposed subpoena for records from the law firm Boies Schiller Flexner LLP, and to also share any documents produced as a result. The letter notes that the government has already provided over 2.7 million pages of discovery to the defense.
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