Epstein Secrets

t initial production is nonsense. As the Court is aware, the EFTA00040543 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's

bmits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, the

legal arguments—more than four months in advance of the deadline for any such motion—relating to the ages of the victims. EFTA00077274 Honorable Alison J. Nathan August 13, 2020 Page 3 ordered disclosure of a certain victim identity shortly after the indictment, the Court noted that the Government had alre

bmits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, the "

t initial production is nonsense. As the Court is aware, the EFTA00084837 Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 2 of 5 Honorable Alison J. Nathan August 13, 2020 Page 2 protective order was docketed on Friday, July 31, 2020'—the timing of which was principally the result of the defendant's

bmits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, 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."),

bmits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, 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."),

bmits that in any event such a motion could not be meaningfully evaluated at this stage, prior to the completion of discovery. See United States v. Mahabub, 13 Cr. 908 (AJN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (denying a motion for a bill of particulars that sought, among other things, the