Epstein Secrets

thern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 21, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States

New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 17, 2020 (the "Defense Letter"), requesting that

ars to be somewhat sparse— perhaps because few defendants attempt such a maneuver—see United States v. Calderon, 15 Cr. 025, 2017 WL 6453344, at *3 (D. Conn. Dec. I, 2017) (discussing the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), se

Southern District of New York The Silvio J. Mao Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States

New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Gleislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to

e identities of .. . victims so that other victims will not be deterred from reporting such crimes." United States v. Paris, 2007 WL 1484974, at *2 (D. Conn. May 18, 2007). Moreover, and consistent with those interests, courts in this Circuit have routinely acknowledged the need to protect victim-witness

Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 9/2/20 20-CR-330 (MN) MEMORANDUM OPINION AND ORDER ALISON J. NATHAN, District Judge: On August 17, 2020, Defendant Ghislaine Maxwell filed a sealed letter motion seeking an Order modifying the protective order in th

protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCR), 2017 WL 6453344, at •2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (L

TES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION AND ORDER ALISON J. NATHAN, District Judge: Defendant Ghislaine Maxwell has been indicted by a grand jury on charges of conspiracy to entice minors to travel to engage in ill

extradition request is pending in Canada and may be subject to withdrawal."); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000) ("[I]t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extr

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

, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 4577303, at *3 (D. Conn. Dec. 26, 2007). Maxwell also argues that compulsion of the materials' production under Rule 17(c) is justified because the materials appear not to

merica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY PILED DOC N: DATE FILED:8/13/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: On April 16, 2021, the Court issued an Opinion & Order granting in part and denying in part Ghislaine Maxwell's various pretrial m

v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *8 (W.D.N.Y. May 8, 2014); United States v. Sensi, No. 3:08-CR-253 (WWE), 2010 WL 2351484, at *3 (D. Conn. June 7, 2010). The sex trafficking charges are therefore not time-barred. Regardless of whether it was the general five-year limitations period in

On June 29, 2020, before she had the opportunity to answer, Ms. Maxwell was indicted by a grand jury. That criminal case is now pending before Judge Nathan, United States v. Maxwell, 20 Cr. 330 (MN). The July 8 Superseding Indictment is attached as Exhibit A ("Indictment"). Notably, the Indictment quot

impose a stay on overlapping civil cases during the pendency of a criminal case. See, e.g., Nesbitt v. Berner, 18-CV-00699 (VLB), 2018 WL 5619716 (D. Conn. Oct. 30, 2018) (granting stay of federal Trafficking Victims Protection Act civil after defendant was charged in state court with patronizing a min

protective orders in the civil context to the criminal context. See, e.g., United States v. Calderon, No. 3:15-CR-25 (JCH), 2017 WL 6453344, at *2 (D. Conn. Dec. I, 2017) (applying the civil standard for the modification of a protective order in a criminal case); United States v. Kerik, No. 07-CR-1027 (L

his matter, the Defendant may make unsealing applications to those Courts if she wishes. SO ORDERED. Dated: September 2, 2020 New York, New York ALISON J. NATHAN United States District Judge 5 EFTA00028059