U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mono Building January 28, 2021 BY ECF & ELECTRONIC MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's order dated January 26, 2021 providing the Government with an opportunity to respond to the defendant's proposed redactions to its pre-trial motions filed on January 25, 2021. The Government notes at the outset that the defendant has not proposed any redactions to certain motions filed on the docket. (Motions 5, 8, 9, & 12; Dkts. 119-126). The Government agrees that no redactions are necessary as to those particular motions. The Government agrees with the defendant's proposed redactions to the remaining pre-trial motions for the following reasons: EFTA000658
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U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mono Building January 28, 2021 BY ECF & ELECTRONIC MAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's order dated January 26, 2021 providing the Government with an opportunity to respond to the defendant's proposed redactions to its pre-trial motions filed on January 25, 2021. The Government notes at the outset that the defendant has not proposed any redactions to certain motions filed on the docket. (Motions 5, 8, 9, & 12; Dkts. 119-126). The Government agrees that no redactions are necessary as to those particular motions. The Government agrees with the defendant's proposed redactions to the remaining pre-trial motions for the following reasons: EFTA000658
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EFTA00031870
Court Filing: 100
The government opposes Ghislaine Maxwell's renewed bail motion, arguing that she remains a flight risk due to the seriousness of the charges, strong evidence against her, and her financial resources and foreign ties. The court had previously denied bail after a thorough hearing, and the government contends that Maxwell's new bail package does not alter the court's prior finding.
GRAND JURY [EFTA00008998]
GRAND JURY EXHIBIT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA SUPERSEDING INDICTMENT GHISLAINE MAXWELL, Defendant. S1 20 Cr. 330 (AJN) COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW The char...
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Moll° Building One Saint Andrew's Plaza New York. New York 10007 December 17, 2020 BY FEDERAL EXPRESS MDC—Metropolitan Detention Center Legal Department 80 29th Street Brooklyn, NY 11232 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Enclosed is discovery pertinent to the following inmate: • Ghislaine Maxwell: 02879-509 Please allow her access to the materials enclosed. by: Enclosure Very truly yours, AUDREY STRAUSS Acting United States Attorney Assistant United States Attorneys EFTA00078333
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