DOJ Letter: Southern D.New, August 13, 2020, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN (EFTA00077273)

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 August 13, 2020 VIA 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 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 10, 2020 (the "Defense Letter" or "Del. Ltr."), requesting that the Court order the Government to disclose the names of certain Government witnesses 11 months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied. A. The Defendant's Demand That the Government Name Certain Trial Witnesses For the third time in as many weeks, the defendant and