U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse May 20, 2021 Re: United States v. Ohislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated May 17, 2021, which directed the Government to confer with defense counsel and submit proposed redactions to Exhibit C to the defendant's memorandum in support of her supplemental pre-trial motions. (Dkt. No. 284). The Government seeks redactions that are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These 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). Today the Government is submitting to the Court by email its proposed
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U.S. Department of Justice United States Attorney Southern District of New York BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse May 20, 2021 Re: United States v. Ohislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated May 17, 2021, which directed the Government to confer with defense counsel and submit proposed redactions to Exhibit C to the defendant's memorandum in support of her supplemental pre-trial motions. (Dkt. No. 284). The Government seeks redactions that are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These 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). Today the Government is submitting to the Court by email its proposed
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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
EFTA00031870
Juror Questionnaire: 2020-cv-00000000-JN Document 6423-11 Filed 03/21/22 Page 515 of 830
Juror ID 50 responded to a questionnaire regarding their ability to serve as a fair and impartial juror. They indicated no association with the NYPD and no opinion that would make it difficult to be impartial regarding the U.S. Attorney's Office.
EFTA00015186
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...
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