U.S. Department of Justice
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U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 13, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with the parties' respective positions regarding juror questionnaires completed on November 12, 2021. I. Prospective Jurors Proceeding to Voir Dire The parties agree that the following prospective jurors should proceed to voir dire: Juror # 570 573 578 581 582 583 586 589 593 594 595 596 602 604 608 611 612 EFTA00094667 Page 2 615 621 622 623 630 637 642 647 651 655 661 667 668 669 670 676 677 680 683 685 690 691 694 II. Prospective Jurors Ex
Persons Referenced (5)
“...ge 5 Juror II 585 617 620 639 656 659 662 684 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern D...”
Defense Counsel“...By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By email) EFTA00094671”
United StatesUnited States AttorneyGhislaine MaxwellTags
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EFTA DisclosureRelated Documents (6)
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 18, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government's 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). Although the Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 14, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with a list of names, places, and relevant entities, for purposes of examining prospective jurors during voir dire. This letter is respectfully requested to be filed under seal to protect the privacy of witnesses and third parties. I. List of Names The following is a list of names that jurors may hear at trial: • Juan Alessi • Maria Alessi • • Janusz Banasiak • • Daniel Besselsen • • • • Michael Buscemi EFTA00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully requests permission to file a reply brief in support of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the defendant's opposition brief raises new arguments about hearsay exceptions that the defendant argues apply to information contained in Dr. Hall's report and further elaborates on the defendant's theory of the report's relevance. The Government proposes to file its responsive brief by noon on November 22, 2021, and to respond only regarding Dr. Hall and not the other experts discussed
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The .Wlvio J. Mello Building One Saint Andrew's Plaza New York, New York 10007 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully requests that Your Honor allow us to arrange for the provision of secure high-speed wired Internet access in the courtroom in connection with trial in the above-captioned matter. The secure Internet connection will enable the trial team in the courtroom to stay connected to our online case repository and resources in the office during critical moments of the proceedings. This will greatly facilitate the effective and efficient presentation of evidence. In addition, we will be able to reduce the files we bring into the courtroom, as well as the traffic to and from the cou
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 7, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with the parties' respective positions regarding juror questionnaires completed on November 5, 2021 and November 6, 2021. I. Prospective Jurors Proceeding to Voir Dire The parties agree that the following prospective jurors should proceed to voir dire: Juror # 2 7 8 12 13 14 20 21 22 23 26 27 28 29 30 EFTA00077389 Page 2 32 33 37 43 47 48 49 50 54 55 58 62 63 70 79 82 87 89 93 96 98 108 112 113 114 117 119 120 123 124 125 126 127 129 1
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of S
Case 1:20-cr-00330-AJN Document 430 Filed 11/10/21 Page 1 of S U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED:11 ill /21 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: The Silvio!. Mono Building One Saint Andrew's Plana New York, New York /0007 November 10, 2021 The parties are ORDERED to submit the lists referenced in this letter on or before November 14, 2021, in accordance with Dkt. No. 427. The parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities a
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