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w York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagluca@h
thought that she would be provided with meaningful discovery with sufficient time to prepare. This assumption also seems incorrect. In its letter to the Court the Government proposes that witness statements be provided a mere four weeks prior to trial, for the important witnesses, and eight weeks for the unimportant wit
w York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagluca@h
thought that she would be provided with meaningful discovery with sufficient time to prepare. This assumption also seems incorrect. In its letter to the Court the Government proposes that witness statements be provided a mere four weeks prior to trial, for the important witnesses, and eight weeks for the unimportant wit
w York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagluca@h
thought that she would be provided with meaningful discovery with sufficient time to prepare. This assumption also seems incorrect. In its letter to the Court the Government proposes that witness statements be provided a mere four weeks prior to trial, for the important witnesses, and eight weeks for the unimportant wit
w York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagluca@h
thought that she would be provided with meaningful discovery with sufficient time to prepare. This assumption also seems incorrect. In its letter to the Court the Government proposes that witness statements be provided a mere four weeks prior to trial, for the important witnesses, and eight weeks for the unimportant wit
w York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, P.0 Jeffrey PagIluca Denver. Colorado www.hmtlaw.com At the initial conference in this case, the Government promised Ms. Max
thought that she would be provided with meaningful discovery with sufficient time to prepare. This assumption also seems incorrect. In its letter to the Court the Government proposes that witness statements be provided a mere four weeks prior to trial, for the important witnesses, and eight weeks for the unimportant wit
Entities connected to both Haddon and the Court the Government

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Foreman
PERSON
Denver
LOCATIONJeffrey Pagliuca
PERSON
Colorado
LOCATION
United States
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATION
New York
LOCATION
Alfredo Rodriguez
PERSON
Brady
PERSON
Bagley
PERSONCollins
PERSONthe New York Stock Exchange
ORGANIZATIONFinnerty
PERSONMiddendorf
PERSONThe Discovery Provided to Date
ORGANIZATIONTeman
PERSONLumpkin
PERSON