Court Filing: 559
Summary
The document is a letter from the U.S. Attorney's Office to Judge Alison J. Nathan regarding the release of certain government exhibits in the Ghislaine Maxwell trial. The parties have agreed on the release of several exhibits with some requiring redactions to protect third-party privacy. The Government is submitting revised versions of certain exhibits into evidence.
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Court Filing: 491
The document is a letter from the US Attorney's Office to Judge Alison J. Nathan arguing that Government Exhibit 52, an address book, is authentic and should not be excluded from evidence. The government contends that Employee-1 can authenticate the exhibit despite not being present when it was removed from Jeffrey Epstein's property. The letter cites case law and provides analogies to support the government's position.
Court Filing: 517
The Government submits a letter to Judge Alison J. Nathan arguing that the defense must disclose exhibits they intend to introduce through Government witnesses as part of their case-in-chief, and that extrinsic evidence for impeachment is narrowly circumscribed. The Government requests that the defense be precluded from offering further undisclosed exhibits absent a showing of cause or an articulation of a valid theory of admissibility.
Court Filing: 554
The document is a letter from the U.S. Attorney's Office to Judge Alison J. Nathan, arguing against certain jury instructions proposed by the defense in the case against Ghislaine Maxwell. The government opposes adding an instruction on the impeachment of witnesses by felony convictions and removing 'equally' from the instruction on uncalled witnesses.
Court Filing: 561
The Government submits a letter to Judge Alison J. Nathan requesting the release of certain Government exhibits admitted during Ghislaine Maxwell's trial, with some exhibits to be temporarily sealed pending the Court's ruling.
Court Filing: 196
The document is a letter from the US Government to Judge Alison J. Nathan updating the court on Ghislaine Maxwell's conditions of confinement at the MDC, detailing her access to discovery materials, communication with attorneys, and search procedures. The Government reports that Maxwell has extensive access to discovery materials and her attorneys, and that the MDC has taken steps to accommodate her needs while maintaining institutional security.
Court Filing: 351
The document is a letter from the US Attorney's Office to Judge Alison J. Nathan, arguing that the court should set an earlier deadline for the defense to file a motion under Federal Rule of Evidence 412. The government proposes a deadline of October 18 or October 25, 2021, instead of November 15, 2021, citing the need for timely resolution of sensitive issues before the trial.
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