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Subject: RE: US v. EpsteinCase 1:20-cr-00330-AJN Document 33 Filed 07/28/20 Page 1 of 7
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efta-efta00084530DOJ Data Set 9Other

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From: 'a" To: a' Cc: Min 1 11 Subject: RE: initial discovery production Date: Sat, 01 Aug 2020 21:02:36 +0000 Attachments: 2020-07-28„govemment_letter_re_protective_orderidocketed).pdf; 2020-07- 31,_GM,memorandum_&_order_granting_govemment_motion.pdf; 2020-07- 31„GM,signed_protective_order (docketed).pdf We wanted to briefly check with you on a few issues. First, I expect that we will very shortly—hopefully Monday, but I expect not later than early this week—be producing materials to you in response to your Touhy request. That has been pending final supervisory approval this week, but we are continuing to follow up with the person who needs to approve and we expect it will go out shortly. As I previously mentioned, we are constrained in our ability to produce any materials obtained in connection with the grand jury process, which are subject to stringent restrictions under Rule 6(e) — I expect that will be noted in the letter, but I mention it given the relatively limited

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DOJ Data Set 9
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EFTA 00084530
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From: 'a" To: a' Cc: Min 1 11 Subject: RE: initial discovery production Date: Sat, 01 Aug 2020 21:02:36 +0000 Attachments: 2020-07-28„govemment_letter_re_protective_orderidocketed).pdf; 2020-07- 31,_GM,memorandum_&_order_granting_govemment_motion.pdf; 2020-07- 31„GM,signed_protective_order (docketed).pdf We wanted to briefly check with you on a few issues. First, I expect that we will very shortly—hopefully Monday, but I expect not later than early this week—be producing materials to you in response to your Touhy request. That has been pending final supervisory approval this week, but we are continuing to follow up with the person who needs to approve and we expect it will go out shortly. As I previously mentioned, we are constrained in our ability to produce any materials obtained in connection with the grand jury process, which are subject to stringent restrictions under Rule 6(e) — I expect that will be noted in the letter, but I mention it given the relatively limited

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Potential Defense Witnesses

“...individuals as part of their investigation, e.g., in individual interviews, any potential defense witnesses and counsel are similarly prohibited from further disclosing or disseminating...”

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From: 'a" To: a' Cc: Min 1 11 Subject: RE: initial discovery production Date: Sat, 01 Aug 2020 21:02:36 +0000 Attachments: 2020-07-28„govemment_letter_re_protective_orderidocketed).pdf; 2020-07- 31,_GM,memorandum_&_order_granting_govemment_motion.pdf; 2020-07- 31„GM,signed_protective_order (docketed).pdf We wanted to briefly check with you on a few issues. First, I expect that we will very shortly—hopefully Monday, but I expect not later than early this week—be producing materials to you in response to your Touhy request. That has been pending final supervisory approval this week, but we are continuing to follow up with the person who needs to approve and we expect it will go out shortly. As I previously mentioned, we are constrained in our ability to produce any materials obtained in connection with the grand jury process, which are subject to stringent restrictions under Rule 6(e) — I expect that will be noted in the letter, but I mention it given the relatively limited volume of disclosable materials. Second, and as we've also previously talked about (though not for some time), now that there is a protective order entered in the Maxwell case, we expect to begin making discovery productions to the defense this coming week. As you may have seen this past week, defense counsel argued that they should be able to publicly identify victims in certain circumstances, which we vigorously opposed. Ultimately the judge ruled in our favor, and the protective order is exceptionally strong. For your reference, the Government's letter on this issue, the Court's decision, and the final protective order are all attached. As you would imagine, some of the discovery we will begin to produce will include information about your client, including information such as her name and date of birth, in connection with documents we have gathered. Consistent with the protective order, defense counsel may not disclose or distribute any discovery materials except under very strict conditions, and in any event the defendant and counsel "are strictly prohibited from publicly disclosing or disseminating the identity of any victims or witnesses referenced in the Discovery." To the extent they need to reference the identity of individuals as part of their investigation, e.g., in individual interviews, any potential defense witnesses and counsel are similarly prohibited from further disclosing or disseminating such identifying information. All of these appropriate restrictions notwithstanding, we nevertheless did want to let you know that we are beginning to make discovery productions, in an abundance of caution and in the interests of transparency. Finally, when we make the initial discovery production, with your permission we may advise defense counsel that each victim in the Indictment is represented by counsel, and identify the counsel for each person (i.e., we would identify you as counsel fo . The reason we would do that would be to preempt attempts at direct contact with represented witnesses by defense counsel or defense investigators. For your client in particular, we not Please let us know if you have a preference on this, and we're also happy to discuss it via phone. As always, please do not hesitate to be in touch on any of these issues, we'll keep you advised of any significant developments, and thanks. Assistant U.S. Attorney EFTA00084530 Southern District of New York EFTA00084531

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Related Documents (6)

Court UnsealedLegal FilingUnknown

Court Filing: 20cr833 (D.N.J. filed 11/18/20)

This court filing outlines the procedures for the defendant and defense counsel to access and handle discovery materials marked as 'highly confidential' by the government. It restricts the dissemination and copying of such materials and requires designated persons and potential defense witnesses to sign an order acknowledging the confidentiality obligations. The order aims to balance the defendant's right to prepare for trial with the need to protect sensitive information.

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DOJ Data Set 9OtherUnknown

Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 177uja-1-44

Case 1:20-cr-00330-AJN Document 37 Filed 07/30/20 177uja-1-44 1M. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0. DATE FILED:7/30/2020 20-CR-330 (MN) MEMORANDUM OPINION & ORDER ALISON J. NATHAN, District Judge: Both parties have asked for the Court to enter a protective order. While they agree on most of the language, two areas of dispute have emerged. First, Ms. Maxwell seeks language allowing her to publicly reference alleged victims or witnesses who have spoken on the public record to the media or in public fora, or in litigation relating to Ms. Maxwell or Jeffrey Epstein. Second, Ms. Maxwell seeks language restricting potential Government witnesses and their counsel from using discovery materials for any purpose other than preparing for the criminal trial in this action. The Government has proposed contrary language on both of these issues. For

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DOJ Data Set 9OtherUnknown

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont

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DOJ Data Set 9OtherUnknown

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont

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DOJ Data Set 7CorrespondenceUnknown

EFTA00009664

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DOJ Data Set 9OtherUnknown

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P

Case 1:20-cr-00330-AJN Document 36 Filed 07/30/20 P UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. x 1nf19 WO USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:7/30/2020 PROTECTIVE ORDER 20 Cr. 330 (AJN) x ALISON J. NATHAN, United States District Judge: WHEREAS the Government intends to produce to GHISLAINE MAXWELL, the defendant, certain documents and materials that (i) affect the privacy and confidentiality of individuals, (ii) would impede, if prematurely disclosed, the Government's ongoing investigation; (iii) would risk prejudicial pretrial publicity if publicly disseminated, and (iv) is not authorized to be disclosed to the public or disclosed beyond that which is necessary for the defense of this action, and other materials pursuant to Federal Rule of Criminal Procedure 16 ("Rule 16") and pursuant to any other disclosure obligations (collectively, the "Discovery"), which cont

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