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A letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan dated December 18, 2021, regarding the Ghislaine Maxwell trial. The Government is writing to oppose the addition of a specific jury instruction (Sand instruction 7-12) concerning the impeachment of witnesses by prior felony convictions, arguing it is not necessary in this context. The letter mentions a witness named 'Carolyn' whose prior convictions were elicited.
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This is a letter from the United States Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter argues that under Rule 613(b), the court has discretion to require that an alleged inconsistent statement be shown to a witness before extrinsic evidence is admitted, citing United States v. Marks.
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This is a letter filed by the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan on December 17, 2021, regarding the case United States v. Ghislaine Maxwell. The Government is writing to limit the scope of cross-examination by the defense of law enforcement agents, specifically stating they will object to questions regarding the agents' 'failure to utilize some particular technique,' citing a prior ruling from November 1, 2021.
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This document is a letter from the U.S. Government to Judge Alison J. Nathan dated December 15, 2021, regarding the case United States v. Ghislaine Maxwell. The Government is requesting permission to redact portions of the defendant's motion seeking testimony from Jack Scarola, Brad Edwards, and Robert Glassman to protect the privacy of a Minor Victim.
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This legal letter from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 14, 2021, opposes defendant Ghislaine Maxwell's request to call three attorneys for victims (Jack Scarola, Brad Edwards, and Robert Glassman) to testify. The Government argues that their testimony about privileged client conversations or discussions with the Government would be irrelevant and an improper attempt to circumvent privilege, as the victims themselves have already testified.
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A letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The Government informs the court that, after conferring with the defense, they will not agree to a stipulation regarding the testimony of Robert Glassman. The Government argues that a specific statement in an email is inadmissible and requires context to be understood by 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. Attorney's Office (SDNY) to Judge Alison J. Nathan dated December 9, 2021, regarding the case United States v. Ghislaine Maxwell. The Government is requesting permission to redact a letter motion concerning the admission of Government Exhibit 52 and to seal or redact Exhibits A and B to protect the privacy of minor victims, witnesses, and third parties.
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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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A formal letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell, dated December 3, 2021. The prosecution and defense have agreed to a testimonial stipulation concerning witness Michael Dawson, and jointly request that the Court release him from the obligation to return to court on the following Monday.
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This is a joint letter from the prosecution and defense in the case of United States v. Ghislaine Maxwell to Judge Alison J. Nathan. The parties inform the court they have been unable to reach an agreement regarding the defense's request for information on Maxwell's detention conditions at the MDC. The Government proposes that MDC legal counsel submit a written response, while the defense insists that Warden Heriberto Tellez appear personally before the Court to address concerns about confinement conditions.
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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 letter from the U.S. Department of Justice to Judge Alison Nathan regarding the case *United States v. Ghislaine Maxwell*. The Government refutes defense accusations of abandoning discovery deadlines, noting they have already produced 350,000 pages and are preparing to release 1.2 million documents from devices seized from Jeffrey Epstein's residences. The letter also addresses complaints regarding the Metropolitan Detention Center (MDC) and asserts compliance with the Court's July 15, 2020 scheduling order.
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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 regarding 'United States v. Ghislaine Maxwell'. The Government requests permission to delay the disclosure of sensitive photographs and documents related to victims of Jeffrey Epstein to the defense until eight weeks before trial, citing risks to an ongoing investigation and victim privacy. The defense counsel has objected to this request.
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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 document is a letter from the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan dated August 21, 2020, regarding United States v. Ghislaine Maxwell. The Government opposes the defendant's request to use confidential discovery materials from this criminal case in unrelated civil litigation. The letter notes that over 165,000 pages of discovery have been produced and argues that the materials in question relate to an ongoing criminal investigation and grand jury proceedings.
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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 is a letter from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The government requests the court enter its proposed protective order and objects to two specific inclusions sought by the defendant, particularly regarding the public naming of victims.
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This document is a letter filed on July 27, 2020, by the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The Government requests time to respond to a defense motion for a protective order, noting that discussions on the matter were ongoing as of the previous evening. At the bottom of the document, Judge Nathan orders a schedule for the response (due July 28) and reply (due July 29), and mandates the parties meet and confer by phone.
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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 letter from the U.S. Attorney to Judge Alison J. Nathan providing an update on Ghislaine Maxwell's confinement conditions at the MDC. The Government asserts that Maxwell receives exceptional access to discovery materials (13 hours/day, 7 days/week) via both a laptop and desktop. A footnote addresses complaints regarding missing emails, stating that an investigation revealed Maxwell deleted or archived them herself, with no evidence of MDC staff misconduct.
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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 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.
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A letter from the U.S. Attorney's Office to Judge Alison J. Nathan dated February 1, 2021, regarding the conditions of Ghislaine Maxwell's confinement at the MDC. The Government addresses a dispute over Maxwell's access to a laptop for reviewing over two million pages of discovery materials on weekends and holidays. While the Government does not object to the access, they defer to MDC management protocols, noting that Maxwell already receives more review time (13 hours/day, 7 days/week) than any other inmate.
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