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efta-efta00018881DOJ Data Set 8Correspondence

EFTA00018881

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DOJ Data Set 8
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efta-efta00018881
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
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 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

Related Documents (6)

Court UnsealedTestimonyUnknown

Court Transcript: 777

The transcript records a court session where the judge addresses jury requests for transcripts of certain witnesses and clarification on the deliberation schedule over the New Year's holiday period. The judge discusses the schedule with counsel and decides to instruct the jury to continue deliberations as needed, including on December 31 and January 1, unless they have unmoveable commitments.

26p
Court UnsealedLegal FilingUnknown

Court Filing: 549

The government files a letter with the court regarding the anticipated testimony of law enforcement agents and the boundaries of cross-examination, citing prior court rulings and relevant case law. The government objects to certain lines of questioning by the defense, including those related to investigative techniques and motives. The letter is submitted in advance of the agents' testimony.

2p
DOJ Data Set 8CorrespondenceUnknown

EFTA00010037

0p
Court UnsealedLegal FilingUnknown

Court Filing: 650

The United States Attorney's office requests that the court exclude time under the Speedy Trial Act from April 1, 2022, to April 22, 2022, due to pending post-trial motions in the case against Ghislaine Maxwell. The defense counsel consents to this request. The court had previously excluded time through April 1, 2022, to allow the parties to research and brief post-trial motions.

2p
Court UnsealedLegal FilingUnknown

Court Order: 637

The court order compels a witness to testify at a hearing in the Ghislaine Maxwell trial, despite their invocation of the Fifth Amendment, and grants them immunity from prosecution for their testimony. The order was approved by the Department of Justice and signed by Judge Alison J. Nathan. The witness's testimony is deemed necessary to the public interest.

2p
Court UnsealedLegal FilingUnknown

Court Filing: 372

The document is a letter from the United States Attorney's Office to Judge Alison J. Nathan regarding the jury selection process in the case United States v. Ghislaine Maxwell. The government requests clarification on when the parties will be provided with the names of prospective jurors and suggests that peremptory challenges be exercised at the conclusion of voir dire. The government argues that providing juror names weeks in advance is not necessary and could be unusual.

3p

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