Defense counsel providing preliminary list of documents for case-in-chief pursuant to Rule 16(b)(1)(A).
Request for testimony of four FBI/Task Force agents pursuant to United States ex. Rel. Touhy v. Regan for the trial of Ghislaine Maxwell.
Legal submission bringing the Pennsylvania Supreme Court's decision in the Bill Cosby case to the court's attention, arguing it supports dismissing counts against Maxwell based on the Epstein Non-Prosecution Agreement.
Request for court order directing MDC to accept defense-prepared hard drives for Maxwell's discovery review.
Listing of 12 reply memoranda to be filed regarding motions to dismiss and suppress evidence, along with procedural details regarding redactions and sealing.
Request for a Bill of Particulars clarifying 29 specific points in the Superseding Indictment regarding dates, locations, identities, and specific acts.
A letter submitting two versions of a Reply Memorandum for Ghislaine Maxwell's Motion for Bail to be filed under seal. The letter explains that redactions are for privacy concerns and to protect confidential information, including financial documents.
Submission of document to the judge (content of letter not on this page, only signature)
Opposition to government's request to delay disclosure of photographs and documents relating to alleged victims of Jeffrey Epstein.
Motion requesting disclosure of victim identities and improvement of confinement conditions.
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