Epstein Secrets

ern District of New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18, 2021 BY E-MAIL 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 Maxwell, S2

ge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to the administrator of the Epstein Victim

ally to the specific requests for them, as discussed above. EFTA00010124 --- PAGE BREAK --- Page 8 rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. III. Conclusion For

Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 April 5, 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 Stases v. Chislaine Maxwell, S2

e Southern District of New York 40 Foley Square New York, New York 10007 Re: United Stases v. Chislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for

g subpoena that "call[s] for the production of the entire investigative file and is accurately described as a fishing expedition"); United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to obtain ident ed evidence rath

Southern District of New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 April 5, 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 Maxwell, S2

ge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for

g subpoena that "call[s] for the production of the entire investigative file and is accurately described as a fishing expedition"); United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980) ("[T]est for enforcement is whether the subpoena constitutes a good faith effort to obtain ident ed evidence rath