Audrey Strauss
PersonRelationship Network
Reciprocal Discovery Request
Government reiterating requests for reciprocal discovery under Rule 16(b) and witness statements under Rule 26.2.
Submission of Information (Context implies closing of a m...
Offer to provide additional information if the Court has questions.
Request for an order directed at Mr. Markus to comply wit...
The U.S. Attorney's office submitted a letter to the Court requesting an order against Mr. Markus for violating a previous order and potentially interfering with a fair trial through an Op-Ed and other comments.
Response regarding defendant's housing safety and eye cov...
Explanation of why defendant is isolated (safety/stress) and denial of eye mask request (contraband).
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Production of discovery materials (one photograph) designated as confidential.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Notification that the government cannot review or produce the contents of 16 discs containing a forensic image of Epstein's computer due to lack of a valid search warrant for the content.
Case 1:20-cr-00330-PAE
The concluding page of a legal document filed with the court, indicating copies were sent to all counsel of record via ECF (Electronic Case Filing).
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Response to defense's March 8 request for FOIA documents and FBI-NY involvement materials.
Response regarding defendant's conditions of confinement ...
Response addressing safety concerns at MDC and the denial of an eye mask request.
Defendant's search and monitoring procedures at MDC
A document submitted to the court detailing the search and safety protocols for a defendant at the MDC.
Defendant's access to laptop and desktop computer for dis...
The Government states its position that the defendant's current computer access (65 hours/week plus optional weekend desktop access) provided by the MDC and BOP is sufficient for discovery review, especially since the trial is six months away.
Redactions regarding Motions 3, 10, and 11
Government response regarding protective orders and redactions for defendant's motions.
Redactions regarding Motions 3, 10, and 11
Government response regarding protective orders and redactions for defendant's motions.
Detention conditions of Ms. Maxwell
This document is a submission to the court from the US Attorney's office regarding Ms. Maxwell's detention conditions. It suggests that Warden Tellez should be directed to provide a first-hand account of why she is being held under such individualized conditions.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Response regarding redactions for the Court's December 28, 2020 Opinion and Order.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Response to defense requests for sealing and an in camera hearing regarding renewed bail application.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Production of discovery materials including financial records from multiple banks and entities.
Grand Jury Subpoena
Cover letter instructing TransUnion not to disclose the subpoena to third parties due to an ongoing criminal investigation.
Opposition to Defense Letter regarding discovery materials
Government argues against defendant's request to use criminal discovery in civil cases.
Proposal for a date to update the Court on sealing position
The Government submitted a letter to Judge Nathan proposing that the Court set a date approximately 180 days in the future for the Government to update its position on sealing in the case.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Government's opposition to defendant's letter requesting witness names and intervention in confinement conditions.
Defendant's housing and access to discovery
A legal filing arguing against the defendant's requests regarding housing and discovery access, stating that the Bureau of Prisons has already granted extensive access to discovery, rendering the application moot.
Argument against defendant's motion and for the Governmen...
A legal document filed by the U.S. Attorney's office arguing that the defendant's attempt to restrict the Government and third parties is unprecedented and lacks legal basis, and requesting the Court to enter the Government's proposed protective order.
Opposition to defendant's motion regarding a protective o...
The U.S. Government argues against the defendant's motion to restrict the Government's use of materials and to place restrictions on third parties, stating the request is unprecedented and without legal basis. The Government asks the Court to deny the defendant's motion and enter the Government's proposed protective order.
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
The Government requests an extension until 5 p.m. the next day to respond to a letter motion for a protective order filed by the defense, noting that discussions for a joint proposal were thought to be ongoing.
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