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efta-efta00027704DOJ Data Set 8Correspondence

EFTA00027704

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DOJ Data Set 8
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efta-efta00027704
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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 The SiAdol Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 18, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government's 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 motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document. In addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government's motions in limine. EFTA00027704 Page 2 Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) EFTA00027705

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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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