court filing: 652
Summary
The US Attorney's office opposes Ghislaine Maxwell's request to stay the proceedings, arguing that the request is based on speculation about an unreleased interview with Juror 50. The government asserts that the court has already conducted a thorough hearing and completed the fact-finding process. The application should be denied, according to the government.
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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.
Court Filing: 359
The US Attorney's Office for the Southern District of New York submits a motion to file its motions in limine with proposed redactions to protect victim and third-party privacy. The redactions are justified under the Lugosch v. Pyramid Co. of Onondaga test. The government requests the court to permit the filing with redactions.
Court Filing: 411
The US Attorney's Office for the Southern District of New York requests that the court reconsider its order requiring the government to file briefing on the admissibility of defense expert witnesses by November 8, 2021. The government argues that the tight deadline is impractical given their existing workload and other trial preparation responsibilities. They propose a revised deadline of November 15, 2021.
Court Filing: 415
The US Attorney's office filed a response to Ghislaine Maxwell's motion for reconsideration regarding the disclosure of juror names, arguing that the defendant's request for early disclosure is not justified and that the court's current plan for juror name disclosure is sufficient. The government contends that the defendant is seeking extra time to conduct research on prospective jurors without a valid reason. The government's response cites relevant case law and the court's previous orders to support its position.
Court Filing: 422
The document is a letter from the US Attorney's office to Judge Alison J. Nathan, detailing the MDC's procedures for handling Ghislaine Maxwell's legal mail and responding to the court's concerns about timely delivery. The MDC has outlined its processes for picking up and delivering legal mail, and stated that additional steps would be burdensome. The Government will continue to inform MDC legal counsel when sending electronic discovery materials.
Court Filing: 524
The US Attorney's office requests that the court inform the jury that Witness-3's testimony is limited by the court's instructions, to mitigate potential prejudice to the Government. The proposed jury instruction aims to clarify the relevance and limitations of Witness-3's testimony regarding interactions with Ghislaine Maxwell and Jeffrey Epstein.
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