Epstein Secrets

thern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 13, 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. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 10, 2020 (the "Defense Letter" or "Def. Ltr."),

d approximately 11 months before trial—nor is the Government aware of any. For example, in the lead case cited by defense counsel, United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged the ability of district courts to compel disclosure of the identity of governme

Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP Mark Chi: v.ci It ,a August 10, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: United States v. Ghislaine Maxw

outhern District of New York United States Courthouse New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: NUN York NY 10022 .1 212 957 7600 phone nvoacclaenTesser corn On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter mot

0 Page 3 District courts have the inherent authority to compel pretrial disclosure of the identities of government witnesses. See United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975). Such disclosure is warranted when there is a specific showing that the disclosure is material to the preparation

thern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 13, 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. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 10, 2020 (the "Defense Letter" or "Def. Ltr."),

d approximately 11 months before trial—nor is the Government aware of any. For example, in the lead case cited by defense counsel, United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged the ability of district courts to compel disclosure of the identity of governme