Epstein Secrets

se 1:20-cr-00330-AJN Document 37 Filed 07/30/20 FAn I of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. IISDC SDNY DOCUMENT ELECTRONICALLY PILED DOC 0. DATE FILED:7/30/2020 20-CR-330 (MN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN

arties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora,

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. IISDC SDNY DOCUMENT ELECT

nguage, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly referenc

he identity of any alleged victim or potential witness referenced in the discovery materials"); see also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for individuals who have spoken on the

, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Ghislaine Maxwell renew our request that the Court release the names of potential jurors, for

Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:

lso the subject of extensive ongoing publicity. We submit that withholding the names of 600 jurors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial jury and is a procedure that would violate due process in this particular case.' "An impartial jur

ors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial

onduct background research on prospective jurors is a "rudimentary practice" during jury selection. United States v. Stone, No. 19-0018 (ABJ), 2020 U.S. Dist. LEXIS 67359, at *93 (D.D.C. Apr. 16, 2020); see also Carino v. Muenzen, No. A-5491-0811, 2010 N.J. Super. Unpub. LEXIS 2154, at *27 (Super. Ct. App

se 1:20-cr-00330-AJN Document 37 Filed 07/30/20 FAn I of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. IISDC SDNY DOCUMENT ELECTRONICALLY PILED DOC 0. DATE FILED:7/30/2020 20-CR-330 (MN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN

arties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora,

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. IISDC SDNY DOCUMENT ELECT

nguage, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly referenc

he identity of any alleged victim or potential witness referenced in the discovery materials"); see also United States v. Corley, No. 13-cr-48, 2016 U.S. Dist. LEXIS 194426, at *11 (S.D.N.Y. Jan. 15, 2016). The Defense argues this interest is significantly diminished for individuals who have spoken on the