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

ocument 269 Filed 05/04/21 Page 7 of 9 Page 7 individual "is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct

erica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey

ware of its Brady obligations and that it has complied and will continue to comply with them. And because the witness statements are covered by the Jencks Act, the Court cannot compel production of such statements under the terms of the statute. See 18 U.S.C. § 3500; Coppa, 267 F.3d at 145. Next, the G

erica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey

ware of its Brady obligations and that it has complied and will continue to comply with them. And because the witness statements are covered by the Jencks Act, the Court cannot compel production of such statements under the terms of the statute. See 18 U.S.C. § 3500; Coppa, 267 F.3d at 145. Next, the G

(S.D.N.Y. Jan. 6, 2010) (declining to order immediate disclosure of Giglio material, because the Government stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States v. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second C

d, in August, after the defendant sought an order directing the Government to disclose to defense counsel the identifies of the Minor Victims, Judge Nathan ruled that the request was premature, noting that production of discovery had just begun and the "parties have not yet engaged in discussions regar