United States Attorney, Southern District of New York
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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.
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This document is a letter dated August 6, 2025, from the U.S. Attorney for the Southern District of New York to Judge Paul A. Engelmayer regarding the case of United States v. Ghislaine Maxwell. The letter serves as a cover sheet for five enclosed submissions from various counsel (John Scarola, Sigrid McCawley, Bradley Edwards, and Neil S. Binder). The Government outlines the filing status of each submission, indicating whether it can be filed publicly without redactions, with redactions, or under seal.
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This is a letter from the U.S. Attorney for the Southern District of New York to Judges Richard M. Berman and Paul A. Engelmayer, dated August 4, 2025. The Government is responding to a court order to provide more information about grand jury materials it has moved to unseal in the criminal cases against Jeffrey Epstein and Ghislaine Maxwell. The letter outlines the specific information requested by the court, which includes dates of grand jury presentations, exhibits shown, and the government's position on unsealing these materials.
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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 document is the signature page (page 5 of 5) of a legal filing, Document 558, in case 1:20-cr-00330-PAE, filed on December 19, 2021. The document was submitted by the office of DAMIAN WILLIAMS, United States Attorney for the Southern District of New York, and signed by Assistant U.S. Attorney Maurene Comey, with Alison Moe, Lara Pomerantz, and Andrew Rohrbach also listed as Assistant U.S. Attorneys on the case.
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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 document is the second page of a legal filing (Document 546) from case 1:20-cr-00330-PAE, filed on December 15, 2021. It contains the signature block for the U.S. Attorney's Office for the Southern District of New York, submitted by U.S. Attorney Damian Williams and signed by Assistant U.S. Attorney Maurene Comey, with three other Assistant U.S. Attorneys also listed. The document indicates that a copy was sent to the Defense Counsel via the court's electronic filing system.
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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 document is the second page of a legal filing (Document 538) in case 1:20-cr-00330-PAE, filed on December 11, 2021. It serves as the signature page for a submission by United States Attorney Damian Williams and Assistant U.S. Attorneys Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach from the Southern District of New York. The document also indicates that a copy was sent to the Defense Counsel via e-mail.
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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 document is the signature page (page 2 of 2) of a court filing in case 1:20-cr-00330-PAE, filed on December 9, 2021. It was submitted by the office of Damian Williams, the United States Attorney for the Southern District of New York, and signed by Assistant U.S. Attorney Maurene Comey. The document also lists Alison Moe, Lara Pomerantz, and Andrew Rohrbach as Assistant U.S. Attorneys and indicates that Defense Counsel was served a copy via the court's electronic filing system.
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This is the signature page (page 8 of 8) of Document 533, a legal filing in case 1:20-cr-00330-PAE, submitted on December 9, 2021. The document is filed by United States Attorney Damian Williams and signed by Assistant U.S. Attorney Maurene Comey on behalf of herself and three other AUSAs from the Southern District of New York. A copy was also sent to the Defense Counsel by e-mail.
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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 is a legal filing from the U.S. Department of Justice to Judge Alison J. Nathan, dated December 4, 2021, in the criminal case against Ghislaine Maxwell. The prosecution is moving to admit photographs from inside Jeffrey Epstein's New York residence as evidence. The government argues that these photographs are relevant to the case because they serve to corroborate the testimony of a witness identified by the pseudonym 'Jane'.
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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 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 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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This legal document is a joint letter dated December 1, 2020, from the prosecution and defense to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The letter details a disagreement between the two parties regarding how to address the defendant's concerns about her conditions of confinement at the Metropolitan Detention Center (MDC). The Government proposes a written response from MDC's legal counsel, while the defense insists on a personal court appearance by the warden, Heriberto Tellez.
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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.
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This is a letter dated August 4, 2025, from the U.S. Attorney for the Southern District of New York to Judges Richard M. Berman and Paul A. Engelmayer. The Government is responding to the Court's July 31, 2025 order, which required it to provide specific information about grand jury materials in the cases against Jeffrey Epstein and Ghislaine Maxwell. The letter outlines the history of motions to unseal these materials and lists the specific information the Court has requested, such as presentation dates, exhibits, and the Government's position on unsealing them.
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This document is the signature page of a court order from the case United States v. Jeffrey Epstein (1:19-cr-00490-RMB), filed on July 25, 2019. The order was signed by Judge Richard M. Berman of the Southern District of New York. It shows consent from both the prosecution, represented by U.S. Attorney Geoffrey S. Berman, and the defense, represented by attorneys Martin Weinberg and Reid Weingarten on behalf of Jeffrey Epstein.
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This document is the signature page of a court order from Case 1:19-cr-00490-RMB, filed on July 25, 2019. It shows the agreement and consent of both the U.S. Government, represented by U.S. Attorney Geoffrey S. Berman's office, and the defense, represented by counsel for Jeffrey Epstein. The order was issued by Judge Richard M. Berman of the Southern District of New York.
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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 Judge Richard M. Berman, filed on July 17, 2019, in the case against Jeffrey Epstein. The prosecution refutes the defendant's claim that an expired Austrian passport was never used, presenting evidence of travel stamps to France, Spain, the UK, and Saudi Arabia from the 1980s. The government also highlights that Epstein has not clarified how he obtained the passport or if he holds citizenship or residency in any other country.
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