EFTA00018881 - EFTA00018882
A formal letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell, submitting the parties' joint request to charge and proposed verdict sheet.
This document is a legal correspondence from the U.S. Attorney's Office for the Southern District of New York, sent via ECF on November 3, 2021. It transmits the joint request to charge and proposed verdict sheet for the United States v. Ghislaine Maxwell trial. The letter details that the defense has objections, noted in redlines and comment bubbles, and explains that the Government proposed redactions based on privacy concerns, citing the Second Circuit's test in Lugosch v. Pyramid Co. of Onondaga. It also mentions an exhibit submitted under seal from another case.
Key Highlights
- •The letter concerns the trial of Ghislaine Maxwell (20 Cr. 330 (MN)), a key figure in the Jeffrey Epstein case.
- •It involves U.S. Attorney Damian Williams and Judge Alison J. Nathan, central figures in the Southern District of New York's prosecution.
- •The document references legal precedents like Lugosch v. Pyramid Co. of Onondaga for justifying redactions to protect third-party privacy.
- •An exhibit from another case is submitted under seal, indicating ongoing sensitive legal proceedings.
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EFTA00018881 - EFTA00018882
Pages
2
Document Content
Page 1 - EFTA00018881
U.S. Department of Justice United States Attorney Southern District of New York LW 1O1x, JVPW mr. November 3, 2021 BY ECF The Honorable Alison 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: Attached please find the parties' joint request to charge and proposed verdict sheet. The Government is docketing a redacted version today and submitting the unredacted versions to the Court. The redline text in the documents reflect the objections of the defense. Further detail of the parties' objections are contained in comment bubbles. The Government has proposed the only redactions in the Request to Charge. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's request to charge is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of a third party. The Government is also providing under seal Exhibit A, which pertains to a defense comment. The defense informs the Government that this exhibit is a document from another case EFTA00018881
Page 2 - EFTA00018882
Page 2 that was not itself publicly docketed and therefore is submitting Exhibit A under seal. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ MIE Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) EFTA00018882
Entities Mentioned
Alison J. Nathan
PERSON • 2 mentions
Damian Williams
PERSON
Ghislaine Maxwell
PERSON • 3 mentions
British socialite and sex trafficker, daughter of Robert Maxwell, accomplice of Jeffrey Epstein
Lugosch
PERSON
Department of Justice
ORGANIZATION
Pyramid Co. of Onondaga
ORGANIZATION
Second Circuit
ORGANIZATION • 2 mentions
Statistics
Pages:2
Entities:7
Avg. OCR:0.9%
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