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, 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
Page: EFTA00018373 →Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:
Page: EFTA00018373 →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
Page: EFTA00018374 →ors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial
Page: EFTA00018374 →bers, not just most of them, are free of interest and bias." United States v. Parse, 789 F.3d 83, 111 (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion char
Page: EFTA00018374 →, 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
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
Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan:
ors until the day of jury selection will deprive Ms. Maxwell of her right to be tried by a fair and impartial
bers, not just most of them, are free of interest and bias." United States v. Parse, 789 F.3d 83, III (2d Cir. 2015). In Parse, a case before Judge Pauley sub nom United States v. Daugerdas, a jury convicted defendant Parse and three of his co-defendants of numerous financial fraud and tax evasion char
re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest
criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. EFTA00040364 Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste
stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.
harsh words from U.S. District Judge William Pauley III in a case that puts the MCC at the heart of a murder cover-up. "I read the autopsy report," Pauley said in a July hearing about the death of former MCC inmate Roberto Grant. "He was beaten to death in a dormitory that people are supposed to be sup
re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest
e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste
stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.
harsh words from U.S. District Judge William Pauley III in a case that puts the MCC at the heart of a murder cover-up. "I read the autopsy report," Pauley said in a July hearing about the death of former MCC inmate Roberto Grant. "He was beaten to death in a dormitory that people are supposed to be sup
stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.
re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest
e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste
harsh words from U.S. District Judge William Pauley III in a case that puts the MCC at the heart of a murder cover-up. "I read the autopsy report," Pauley said in a July hearing about the death of former MCC inmate Roberto Grant. "He was beaten to death in a dormitory that people are supposed to be sup
ING ATTORNEY: Kerrie L. Campbell [name of attorney, whh firm, address. glione number and e-mail] KCampbell-Law, PLLC BOIES SCHILLER FLEXNER UP v. Maxwell OPPOSING ATTORNEY:Sigrid moe-awieY 1629 K St., NW, Suite 300, Washington, DC 20006 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 2
co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/designation)
co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/design
ument 153-2, 03/19/2019, 2521600, Page12 of 13 grand jury will not be held up to public ridicule"). Similar considerations recently motivated Judge Pauley to order the redaction of the names of non-parties from warrant materials filed in connection with the Michael Cohen case. See United States v. Coh
Entities connected to both Ghislaine Maxwell and Pauley

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Les Wexner
PERSONFBI
ORGANIZATION
Alison J. Nathan
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSON
Sarah Kellen
PERSON
Michael Jackson
PERSON