Epstein Secrets

ey Southern District of New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 May 4, 2021 BY ECF The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Marvel!, S2

ge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Marvel!, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of April 27, 2021, regarding the defendant's request for an o

that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020). The defendant's request for the entire diary is likely to sweep in a signific

tates of America, —v— Ghislaine Maxwell, Defendant. USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 4/27/21 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: Defendant Ghislaine Maxwell seeks an order authorizing a subpoena pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Proce

ests in civil litigation. 3 EFTA00020300 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 252 Filed 04/27/21 Page 4 of 9 See United States v. Avenatti, No. (SI) I9-CR-373 (PGG), 2020 WL 86768, at *6 (S.D.N.Y. Jan. 6, 2020). But Rule 17(c) subpoenas are not tools of discovery. Nixon, 418 U.S. at 698

ally impeaching statements `ripen into evidentiary material. . . only if and when the witness testifies at trial...." (citation omitted)). See also Avenatti, 2020 WL 86768, at *6 (rejecting the argument that the defendant needed the recordings in question prior to trial in order "to demonstrate witnesses

r potential witnesses that going forward it will not hesitate to take appropriate action in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict compliance" with the rules and "ensure that the Defendant's right to a fair trial will be safeguarded." Id. On July

al jurors, to incriminating evidence that the law has determined may not be used to support a conviction"), cited with approval in United States v. Avenatti , (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020). Based on these cases, the Court may make specific findings supporting the sealin