Epstein Secrets

t the attachments to the Defense Letter be filed under seal. EFTA00091328 Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 2 of 5 Honorable Alison J. Nathan August 21, 2020 Page 2 In particular, the Defense Letter seeks this Court's authorization to use materials relating to applications the Governmen

are of any. Though precedent on this issue appears 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

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

decisions that do exist have rejected the kind of blurring of the line between criminal and civil proceedings that the defendant attempts here. See Calderon, 2017 WL 6453344, at 5-6 (denying a defendant's application for modification of a criminal protective order so he could use certain discovery materi

are of any. Though precedent on this issue appears 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

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

nd Circuit have applied the standard for modification of 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

nd Circuit have applied the standard for modification of 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

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