Case Fileefta-efta00066546DOJ Data Set 9Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7
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Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7
Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7 H A D D O N M O R G A N FOREMAN October 23, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagluca@hmflaw.com At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce "prior investigative files from another investigation in the Southern District of Florida," which it characterized as part of "the core of the case" against Ms. Maxwell,'- after a "careful and exhaustive and through review of all of the materials," with the "bulk" of the discovery produced by "the end of this summer [
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