Epstein Secrets

ounsel can meaningfully investigate the alleged conduct, which is now over 25 years old. Second, we request that the Court enter an order directing the Bureau of Prisons ("BOP") to release Ms. Maxwell into the general population and provide Ms. Maxwell with increased access to the discovery materials while she is de

outweigh the privacy interests of alleged victims referenced in the indictment and warrant the disclosure of their identities. See United States v. Warme, No. 09CR19A, 2009 WL 427111, at *2 (W.D.N.Y. Feb. 20, 2009) (ordering government to disclose identity of sex crime victim where "defendant's abili

574 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 4 of 6 The Honorable Alison J. Nathan August 10, 2020 Page 4 See Warme, 2009 WL 427111, at *2 (ordering government to disclose identity of sex crime victim where "the government has not demonstrated that disclosing the

Government witnesses 1I months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied. A. The Defendant's Demand That the Government Name Certain Trial Witnesses For the third time in as many weeks

etion of discovery production and in the context of pretrial motions. Those circumstances plainly are not present here. Finally, in United States v. Warme, a Western District of New York opinion from 2009 that has never been cited by another court, although the Court ' The Defense Letter states that t

Government witnesses 1I months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied. A. The Defendant's Demand That the Government Name Certain Trial Witnesses For the third time in as many weeks

etion of discovery production and in the context of pretrial motions. Those circumstances plainly are not present here. Finally, in United States v. Warme, a Western District of New York opinion from 2009 that has never been cited by another court, although the Court ' The Defense Letter states that t