Epstein Secrets

Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 April 5, 2021 BY ECF The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United Stases v. Chislaine Maxwell, S2

e Southern District of New York 40 Foley Square New York, New York 10007 Re: United Stases v. Chislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for

he undue harassment of a cooperating witness is a legitimate governmental interest giving rise to standing in this context."); cf. United States v. Nachamie, 91 F. Supp. 2d 552, 558-60 (S.D.N.Y. 2000) (concluding that the Government failed to establish a legitimate interest where, among other things, no

Southern District of New York The SilWoJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 April 5, 2021 BY ECF The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2

ge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of March 24, 2021, regarding the defendant's application for

he undue harassment of a cooperating witness is a legitimate governmental interest giving rise to standing in this context."); cf. United States v. Nachamie, 91 F. Supp. 2d 552, 558-60 (S.D.N.Y. 2000) (concluding that the Government failed to establish a legitimate interest where, among other things, no

erica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

erica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC N: DATE FILED: 4/16/21 20-cr-330 (AJN) OPINION & ORDER ALISON J. NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

merica, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 4/16/21 20-cr-330 (MN) OPINION & ORDER ALISON J. NATHAN, District Judge: In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey

ict. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at *9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of

d, in August, after the defendant sought an order directing the Government to disclose to defense counsel the identifies of the Minor Victims, Judge Nathan ruled that the request was premature, noting that production of discovery had just begun and the "parties have not yet engaged in discussions regar

ally found that disclosures made approximately 30 to 45 days prior to trial constitute "reasonable notice" to defendants) (quoting United States v. Nachamie, 91 F. Supp. 2d 565, 577 (S.D.N.Y. 2000); Giffen, 379 F. Supp. 2d at 344 (Rule 404 does not obligate the Government to provide "unduly early notice