Epstein Secrets

ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730

atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und

e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just

ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730

atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und

e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just

761, 2014 WL 5366107 (S.D.N.Y. Oct. 14, 2014) (Marrero, J.); United States v. Rajaratnam, 753 F. Supp. 2d 317 (S.D.N.Y. 2011) (I lolwell, J.); and United Stales v. McClure, No. CRIM.A. 10-028, 2010 WL 3523030 (E.D. La. Sept. 1, 2010)).) The subpoenas found permissible in Yudung Zhu, in particular, sought a

N.Y. 2008) (Scheindlin, J.), as amended (Feb. 20, 2008)—has suggested applying a different standard, and that standard has generally been rejected. See United States v. Bergstein, 16-CR-746 (PKC), 2017 WL 6887596, at '4 (S.D.N.Y. Dec. 28, 2017) (Castel, J.) ("'iT]he overwhelming majority of district courts in th

in, J.), as amended (Feb. 20, 2008)—has suggested applying a different standard, and that standard has generally been rejected. See United States v. Bergstein, 16-CR-746 (PKC), 2017 WL 6887596, at '4 (S.D.N.Y. Dec. 28, 2017) (Castel, J.) ("'iT]he overwhelming majority of district courts in the Second Circ

ers to the Court so that the information can be made available to Maxwell, if appropriate, at the conclusion of each witness's direct testimony. See United States v. Giampa, No. S 92-CR-437 (PKL), 1992 WL 296440, at *3 *4 (S.D.N.Y. Oct. 7, 1992); United States v. Ferguson, No. 3:06-CR-137 (CFD), 2007 WL 457730

atory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR- 579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations und

e Government's briefing regardless of standing as part of its duty to ensure that the subpoena meets the requirements of Nixon. See United States v. Bergstein, No. I6-CR-746 (PKC), 2017 WL 6887596, at *3 (S.D.N.Y. Dec. 28, 2017). But ex parte Rule 17(c) subpoenas are possible in some circumstances if just

rements for four, independent reasons. First, the Subpoena is overbroad and non-specific, and a clear fishing expedition to "see what may turn up." See United States v. ilvenatti,No. (81) 19 CR. 373 (PGG), 2020 WL 86768, at *4 (S.D.N.Y. Jan. 6, 2020) (denying motion for issuance of Rule 17(c) subpoena). "Subpoen

Defendant can therefore procure from the Government. Thus, a Rule 17(c) subpoena to BSF for those documents is improper. See, e.g., United States v. Bergstein, No. 16 Cr. 746 (PKC), 2017 WL 6887596, at *5 (S.D.N.Y. Dec. 28, 2017) ("When `many' of the subpoenaed materials are obtainable through the discove

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 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order o

the Government has various disclosure obligations. United States v. Cole, No. 19 Cr. 869 (ER), 2021 WL 912425, at *2 (S.D.N.Y. Mar. 10, 2021); see Bergstein, 2017 WL 6887596, at *3. Finally, the Government has standing to challenge subpoenas that call for its own communications. See United States v. Cart