A joint letter submitted to Judge Alison J. Nathan by the U.S. Attorney's Office and Defense Counsel in the case of United States v. Ghislaine Maxwell. The document outlines agreed-upon procedures and disagreements regarding the protection of witness identities during the upcoming trial, including the use of pseudonyms, voir dire protocols to screen jurors, specific jury instructions, and the use of physical binders for sealed exhibits to prevent public viewing. It includes a heavily redacted chart meant to map true witness names to their trial pseudonyms.
This document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan in the case of United States v. Ghislaine Maxwell. The Government argues for the entry of its proposed protective order regarding discovery materials, specifically opposing the defendant's request to publicly name victims who have previously spoken to the media and opposing restrictions on the Government's use of its own investigative materials. The document includes the full text of the proposed protective order, detailing how 'Confidential' and 'Highly Confidential' information (including sexualized imagery) must be handled by the defense.
A letter from the U.S. Attorney's Office to Judge Alison Nathan regarding the Ghislaine Maxwell trial. The government requests clarification on two points: limiting cross-examination details about witnesses' specific acting roles (e.g., genre of movies) to prevent identification, and barring courtroom sketch artists from drawing exact likenesses of witnesses testifying under pseudonyms.
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'.
A legal letter from the U.S. Attorney's Office (SDNY) to Judge Alison Nathan regarding United States v. Ghislaine Maxwell. The Government consents to defense requests to redact the identities of proposed bail cosigners to protect their privacy but objects to holding a sealed 'in camera' hearing for the bail application, citing the public's and victims' right to observe proceedings.
This is a letter dated July 27, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan of the Southern District of New York. The attorneys request the court to enter a protective order for discovery materials in the case of United States v. Ghislaine Maxwell. The letter highlights that while most terms have been agreed upon with the government, two key disputes remain: whether government witnesses should face the same restrictions as the defense regarding discovery materials, and whether the defense should be allowed to identify alleged victims or witnesses who are already public.
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.
This document is a letter filed on December 30, 2020, by 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 prosecutors inform the court that, after conferring with the defense, both parties agree that no redactions are necessary for the Court's December 28, 2020 Opinion and Order denying Maxwell's renewed bail motion. Consequently, they have no objection to the order being filed publicly in its entirety.
This legal document is a letter dated December 15, 2020, from attorney Sigrid S. McCawley to Judge Alison J. Nathan, which includes a statement from Annie Farmer. Farmer, identifying herself as a victim, vehemently opposes Ghislaine Maxwell's motion for bail, characterizing Maxwell as a manipulative psychopath and a significant flight risk who has lived a parasitic lifestyle. The statement argues that releasing Maxwell would prevent justice for her and other victims.
This document is a letter dated June 27, 2022, from attorney Sigrid S. McCawley to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. McCawley explains that her client, victim Virginia Giuffre, cannot physically attend a court hearing due to a medical issue and requests permission to read Giuffre's statement on her behalf. A handwritten note on the document, signed by Judge Nathan, grants this request, ordering that counsel will be permitted to read a shortened version of the statement.
This document is a letter filed on June 26, 2022, by the U.S. Attorney's Office (SDNY) to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The Government is responding to a court order concerning an application by Sarah Ransome and Elizabeth Stein to speak at Maxwell's sentencing. The letter references a previous order where the Court declined to allow individuals not proven at trial to be directly harmed to speak at the hearing, instead permitting them to submit written statements.
This document is a letter filed on June 24, 2022, from attorney Sigrid S. McCawley to Judge Alison J. Nathan regarding the sentencing of Ghislaine Maxwell. It serves to submit a written victim impact statement from Teresa Helm, who identifies herself as a victim trafficked by Maxwell in 2002 at the age of 22. Helm's statement directly addresses Maxwell, describing the grooming process, the psychological trauma endured, and the devastating long-term effects on her self-worth and life trajectory.
This legal document is a letter dated June 22, 2022, from attorney Sigrid S. McCawley to Judge Nathan regarding the sentencing of Ghislaine Maxwell. The letter submits the victim impact statement of Virginia Giuffre, who details being trafficked and abused by Maxwell and Jeffrey Epstein from the age of 16. Giuffre's statement directly blames Maxwell for spotting her at Mar-a-Lago in 2000 and introducing her to Epstein, thereby 'opening the door to hell'.
This legal document is a letter dated June 7, 2021, 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 for defendant Ghislaine Maxwell at the Metropolitan Detention Center (MDC), stating that she receives more time and resources for discovery review than any other inmate. Specifically, it details her 13-hour daily access to computers, her ability to communicate with attorneys, and her extended time outside her cell.
This document is a letter dated December 15, 2020, from Annie Farmer to Judge Alison J. Nathan of the Southern District of New York. In the statement, submitted via her attorney Sigrid S. McCawley, Farmer strongly opposes Ghislaine Maxwell's motion for bail, detailing her personal experience of being sexually abused by Maxwell as a child. Farmer characterizes Maxwell as a manipulative psychopath and a significant flight risk who lacks remorse for her role in procuring girls for Epstein.
This document is a letter from the U.S. Government to Judge Alison J. Nathan, filed on October 15, 2021, in the case of United States v. Ghislaine Maxwell. The letter responds to a court order regarding the delivery of the defendant's legal mail at the Metropolitan Detention Center (MDC). The Government explains the standard procedures at the MDC, noting that mail from counsel is delivered within a business day, while mail from the Government sent via FedEx undergoes a more complex warehouse processing and logging system before reaching the inmate.
A letter motion filed by the U.S. Department of Justice on January 18, 2022, requesting Judge Alison J. Nathan to exclude time under the Speedy Trial Act for Counts 7 and 8 of the Ghislaine Maxwell case until April 1, 2022. The document includes a handwritten endorsement and order signed by Judge Nathan on January 19, 2022, granting the request to allow parties to research and brief post-trial motions. The filing indicates that defense counsel consented to the request.
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