Epstein Secrets

ance with two critical issues that greatly impact Ms. Maxwell's ability to receive a fair trial on the schedul

ison J. Nathan United States District Court Southern 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

client, Ghislaine Maxwell, we respectfully submit this letter motion seeking the Court's assistance with two critical issues that greatly impact Ms. Maxwell's ability to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an order directing the government to dis

e New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: NUN

0 Page 3 District courts have the inherent authority to compel pretrial disclosure of the identities of government witnesses. See United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975). Such disclosure is warranted when there is a specific showing that the disclosure is material to the preparation

ited States District Court Southern District of 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 (t

, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

d approximately 11 months before trial—nor is the Government aware of any. For example, in the lead case cited by defense counsel, United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged the ability of district courts to compel disclosure of the identity of governme

tective order expressly precludes. See Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) (Dkt. 1100). Mor

ited States District Court Southern District of 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 (t

, New York 10007 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

d approximately 11 months before trial—nor is the Government aware of any. For example, in the lead case cited by defense counsel, United States v. Cannone, 528 F.2d 296, 301 (2d Cir. 1975), although the opinion acknowledged the ability of district courts to compel disclosure of the identity of governme

tective order expressly precludes. See Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) (Dkt. 1100). Mor