Epstein Secrets

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

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

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."),

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

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."),

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