Court Filing - Letter: 716
Summary
The defense, represented by Christian R. Everdell, submits a letter to Judge Alison J. Nathan stating that they have no edits to the proposed limiting instructions, but requests the opportunity to respond to the government's submission.
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Letter to the Judge: 273
The letter informs Judge Nathan that the defense will be filing an Omnibus Memorandum in Support of Ghislaine Maxwell's Supplemental Pretrial Motions under seal due to the presence of Confidential Information. The defense will submit the documents to the Court and the government via email, allowing the government to propose redactions as necessary.
Letter to the Judge: 296
The letter, written by Christian R. Everdell, informs Judge Alison J. Nathan that the defense will be filing a sealed Omnibus Reply Memorandum due to the presence of confidential information governed by a Protective Order. The memorandum will be submitted via email to the Court and the government, allowing the government to propose redactions. The letter follows prior practice in handling sensitive information in the case.
Court Filing - Letter to Judge: 310
The defense attorney for Ghislaine Maxwell submits a letter to Judge Alison J. Nathan, drawing parallels between Maxwell's case and the recent Pennsylvania Supreme Court decision in Commonwealth v. Cosby, arguing that the government reneged on its promise not to prosecute Maxwell, similar to the Cosby case. The letter requests the court to consider this new precedent in deciding on the pending motion to dismiss certain counts of the indictment against Maxwell.
Court Filing - Letter to Judge: 35
The letter is from Ghislaine Maxwell's defense attorneys to Judge Alison J. Nathan, arguing against the government's proposed language for a protective order, specifically regarding referencing individuals who have publicly identified themselves. Maxwell's defense team asserts that individuals who have publicly spoken about their allegations against Maxwell or Epstein should not be considered to have privacy interests that need protection.
Court Filing - Letter to Judge: 489
The defense attorney for Ghislaine Maxwell responds to the government's request to find certain birth certificates self-authenticating, agreeing to stipulate to the authenticity of some but not others due to insufficient foundation. The defense is willing to reconsider its position if the government provides necessary attestations and certifications. The letter is addressed to Judge Alison J. Nathan in the United States District Court for the Southern District of New York.
Court Filing - Letter to Judge: 718
The defense submits a letter to Judge Nathan opposing the government's request to modify the Court's proposed limiting instruction regarding Witness-3's testimony, arguing that the instruction is appropriate and balanced. The government wants to call Witness-3, who is not a victim of the charged crimes, and the defense is concerned about potential prejudice to Maxwell.
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