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EFTA00009895.pdf
An email dated April 20, 2021, from an Assistant US Attorney in the Southern District of New York to Ghislaine Maxwell's defense team (Everdell, Cohen, Sternheim, Menninger, Pagliuca). The email serves filing notice for a letter regarding redactions to the defense's reply briefs in the case US v. Maxwell, 20 Cr. 330 (AJN).
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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.
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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.
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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.
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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.
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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.
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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 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.
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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.
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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.
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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.
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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.
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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.
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This legal document is a letter dated July 15, 2019, from the U.S. Attorney for the Southern District of New York to Judge Richard M. Berman regarding the case *United States v. Jeffrey Epstein*. The prosecution requests the exclusion of speedy trial time for the period of July 15-18, 2019, noting that Epstein's defense counsel consents to the request. The document is endorsed by Judge Berman, who granted the application on July 16, 2019.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Richard M. Berman, dated July 12, 2019, arguing against Jeffrey Epstein's motion for pretrial release. The government portrays Epstein as an unrepentant serial sexual predator who poses a significant flight risk due to his vast wealth and the likelihood of a life sentence. The letter cites substantial evidence, including photographs found in his mansion and a history of witness manipulation, to support its request for continued detention.
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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 regarding the case of Ghislaine Maxwell. The government states it does not object to Maxwell's request for weekend laptop access to review discovery materials but ultimately defers to the Metropolitan Detention Center's (MDC) policies. The letter emphasizes that Maxwell has already been provided with extensive access, including a dedicated laptop and desktop computer, for more hours than any other inmate.
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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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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 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 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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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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