EFTA00023892 - EFTA00023893
Internal prosecution email thread from August 2021 showing federal prosecutors at the Southern District of New York drafting and reviewing jury instructions (Requests to Charge) for the Ghislaine Maxwell trial.
This is an internal email chain among Assistant United States Attorneys in the Southern District of New York dated August 6-17, 2021, approximately four months before Maxwell's December 2021 trial. The prosecutors are circulating drafts of the 'RTC' (Requests to Charge) - the proposed jury instructions they would submit to Judge Alison Nathan. The emails discuss resolving potential issues with statutory language in the indictment and whether to amend, redact, or withhold portions from the jury. The redacted sender names suggest this was released through FOIA or civil litigation with attorney identities protected.
Key Highlights
- •Internal SDNY prosecution team correspondence preparing jury instructions for Maxwell trial
- •Prosecutors discussing whether to file a 'cleanup superseder' to fix statutory language issues in the indictment
- •Discussion of alternatives including not giving the indictment to the jury or amending/redacting it
- •Drafted approximately 4 months before Maxwell's conviction on December 29, 2021
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EFTA00023892 - EFTA00023893
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Page 1 - EFTA00023892
From: To: Subject: Date: Tue, 17 Aug 2021 14:45:06 +0000 Attachments: Maxwell RTC v7.moe.LP (MC).doex • :Ira t Thanks My comments/edits attached. From: Sent: Frida Au ust 13 2021 11:00 AM To: Subject: RE: Draft RTC Thanks so much Some small suggestions on top of comments. From: Sent: Wednesday, August 11, 20218:01 PM To: Subject: RE: Draft RTC Thanks, l)rid -just a nudge to look at this when you have a chance? I'd like to get this up to sometime = soon. From: Sent: Monday, August 9, 2021 4:14 PM To: Subject: RE: Draft RTC Thanks very much. Attached are some comments. Once the team has had a chance to review, we can discuss whether we might want to do a "cleanup" superseder to fix any statutory language in the indictment, or whether any issues are either harmless or can be resolved by not giving the indictment to the jury (or amending/redacting the version that goes back to cure any issues). Thanks! From: Sent: Friday, August 6, 2021 7:28 PM To: u ject: Drat RTC Hi all, EFTA00023892
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Attached is a draft RTC for your review. I've left in some comment bubbles to flag some of the judgment calls, and I'm going to clean up the cites/do a citecheck. Looking forward to your comments. ..hanks Assistant United States Attorney Southern District of New York New York, New York 10007 EFTA00023893
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