Silvio J. Mollo
PersonRelationship Network
EFTA00017085.pdf
This document is a formal discovery letter from the US Attorney's Office (SDNY) to the defense counsel for Ghislaine Maxwell, dated August 5, 2020. It lists a comprehensive index of evidence provided to the defense, including financial records from multiple banks (Citibank, Chase, TD Bank, etc.), travel records (flight manifests and airline records), email account records (Oath, Microsoft, Google), and corporate filings (USVI, Delaware). While the document *lists* the existence of flight manifests and financial records, it is an index only and does not contain the specific content (flight paths, transaction amounts) within the document itself.
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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 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 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 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 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 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 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 Notice of Appeal filed on March 24, 2021, in the U.S. District Court for the Southern District of New York on behalf of defendant Ghislaine Maxwell. The appeal challenges a court order from March 22, 2021, which denied her 'Third Motion for Release on Bail'. The document identifies Maxwell's attorney, David Oscar Markus, and the prosecuting Assistant U.S. Attorneys.
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This legal document is a letter from the U.S. Attorney for the Southern District of New York to the Clerk of the Second Circuit Court of Appeals regarding the case of United States v. Ghislaine Maxwell. The letter cites the precedent set in United States v. Watkins to argue that the Bail Reform Act permits a court to conduct a fact-based, "conduct-specific inquiry" for felonies involving a minor victim, rather than being limited to the legal elements of the charge. This submission is intended to provide supplemental authority to the court concerning the upcoming argument in Maxwell's case.
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This document is a Notice of Appeal filed on March 24, 2021, on behalf of Ghislaine Maxwell in the case of United States v. Ghislaine Maxwell (20-CR-00330-AJN). The appeal is directed to the U.S. Court of Appeals for the Second Circuit and challenges the District Court's order from March 22, 2021, which denied her third motion for release on bail. The document lists Maxwell's counsel as David Oscar Markus and the Assistant U.S. Attorneys as Maurene Comey, Alison Moe, and Lara Pomerantz.
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This legal document is a letter dated June 26, 2022, from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan. The letter serves as a court filing in the case of United States v. Ghislaine Maxwell. In it, the government submits a motion filed by the attorney for an individual named 'Kate', which was attached to her victim impact statement, in response to a court order issued that same day.
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The U.S. Attorney for the Southern District of New York submitted a letter motion to Judge Alison J. Nathan in the criminal case against Ghislaine Maxwell. The motion, dated May 11, 2022, requests the exclusion of time under the Speedy Trial Act for two counts until Maxwell's scheduled sentencing on June 28, 2022. The government intends to dismiss these counts but seeks the exclusion as a precaution, noting that the defense counsel consents to the request, which was granted by the judge.
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This is a letter dated April 25, 2022, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan regarding the case against Ghislaine Maxwell. The Government requests that the court order the Probation Office to complete its revised Presentence Investigation Report (PSR) earlier than the currently scheduled date of June 21, 2022. The letter argues that the current schedule, which has the revised PSR due on the same day as the defendant's sentencing submission, does not allow the parties sufficient time to incorporate the report's findings into their own submissions before the June 28 sentencing.
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This legal document is a letter dated April 1, 2022, from the U.S. Attorney for the Southern District of New York to Judge Alison J. Nathan. The government requests an extension, specifically an exclusion of time under the Speedy Trial Act, until April 22, 2022, for Counts Seven and Eight in the criminal case against Ghislaine Maxwell. This extension is sought to allow parties to continue researching and briefing pending post-trial motions, which the government argues is in the interests of justice.
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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, dated March 29, 2021, regarding the case of United States v. Ghislaine Maxwell. The government seeks to clarify a previous statement from October 2020 where it claimed no involvement by its prosecution team in an earlier 'Florida Investigation'. The letter now states that new information suggests the FBI's New York Office may have participated in that Florida investigation between 2005 and 2010, and the government is reviewing files to determine the extent of the interaction.
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This legal document is a joint letter dated January 10, 2022, from the U.S. Attorney's Office for the Southern District of New York to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter proposes a schedule for sentencing and the resolution of severed perjury counts as directed by the court. The Government's position is to schedule the sentencing proceeding approximately three to four months from the date of the letter to allow time for a Presentence Investigation Report and resolution of post-trial motions.
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The U.S. Department of Justice submitted a letter to Judge Alison J. Nathan regarding the criminal case against Ghislaine Maxwell. The letter informs the court that a juror has given multiple press interviews, revealing that he was a victim of sexual abuse and asserted that he "flew through" the juror questionnaire. The government brings these statements to the court's attention as they may have implications for the integrity of the jury selection process.
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