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Case 1:20-cr-00330-PAE Document 335 Filed 09/03/21 Page1of3
UNITED STATES DISTRICT COURT USDC SDNY
SOUTHERN DISTRICT OF NEW YORK cake beiencine
ELECTRONICALLY FILED
DOC #:
DATE FILED: 9/3/21
Unite
Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page1of10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
20 Cr. 330 (AJN)
Vv.
GHISLAINE MAXWELL,
Defendant
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page9of10
no other theory of relevance (including that the materials are exculpatory or otherwise relate to
the criminal charges at issue), and on t
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page8of10
communication of information of any kind.” As a general matter, the use of the terms “all” and
“any” “do not evince specificity.” United S
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 7 of10
to justify the relevance of that evidence; she does not claim, for instance, that that evidence is
exculpatory or that the evidence is o
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page6of10
B. Subpoena Recipient-2
The proposed subpoena to Subpoena Recipient-2 contains four requests. The first seeks
any contingent fee and enga
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page5of10
improper to issue a Rule 17(c) subpoena where the sole relevance of the requested materials is
impeachment. There is no plausible claim th
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page4of10
warrant the issuance of a Rule 17(c) subpoena. See Dkt. No. 298, June 2, 2021 Order, at 1-2.
Maxwell’s other theories of relevance similar
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page3of10
Recipient-1’s original journal for inspection and copying; (3) a pair of black boots that Maxwell
and Jeffrey Epstein allegedly gave to Su
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 2 of10
an item is not discoverable under Rule 16, a party cannot make it discoverable simply by
subpoenaing it under Rule 17. United States v.
Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page1of10
UNITED STATES DISTRICT COURT eric |
SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED
DOC #: ri ani ieee
DATE FILED: 8/13/21
United Sta
_ Casast: 220 OCkRBP MON Dmmunenitaa2 AnbeOte0ls211 Payage afaf 3
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
USDC SDNY One Saint And
__ Case 1:20-cr-00330-PAE Document 332 Filed 09/01/21 Page1of3
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
N
Case 1:20-cr-00330-PAE Document 331
Cy
HADDON
MORGAN
FOREMAN
August 30, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New Y
Case 1:20-cr-00330-PAE Document 328 Filed 08/25/21 Pagelof1
800 Third Avenue
New York, NY 10022
COHEN & GRESSER LLP +1 212.957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-760
Case 1:20-cr-00330-PAE Document 325 Filed 08/23/21 Page1of2
UNITED STATES DISTRICT COURT ee
SOUTHERN DISTRICT OF NEW YORK DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/23/21
United States of
Case 1:20-cr-00330-PAE Document 323 Filed 08/19/21 Pagelof2
800 Third Avenue
New York, NY 10022
COHEN & GRESSER LLP +1 212.957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-760
Case 1:20-cr-00330-PAE Document 324 Filed 08/20/21 Page1of2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New
Cétash: 2Q20rOCRReP AON Demument220 ArbelOes15y221 Pateg2 afef 4
Honorable Alison J. Nathan
August 18, 2021
Page 2
The Government will produce Jencks Act material and its proposed exhibit list
subst
Cétash: 2Q20r OCR ReP AON Demument220 ArbelOes16y221 Pategeé dfof 4
Honorable Alison J. Nathan
August 18, 2021
Page 4
Insofar as the defendant claims that identification of uncharged co-conspirators
Case 1:20-cr-00330-PAE Document 320 _ Filed 08/18/21 Page4of4
Honorable Alison J. Nathan
August 18, 2021
Page 4
Insofar as the defendant claims that identification of uncharged co-conspirators is
ne
Case 1:20-cr-00330-PAE Document 320 _ Filed 08/18/21 Page2of4
Honorable Alison J. Nathan
August 18, 2021
Page 2
The Government will produce Jencks Act material and its proposed exhibit list
substant
Case 1:20-cr-00330-PAE Document 318 Filed 08/13/21 Page1lof2
UNITED STATES DISTRICT COURT USDC SDNY
SOUTHERN DISTRICT OF NEW YORK cansaaeors |
ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/13/21
Unite
Case 1:20-cr-00330-PAE Document317 Filed 08/13/21 Page12o0f14
contended specifically that the indictment is too vague because it refers to open-ended time
periods for the Mann Act counts. The Court d
Case 1:20-cr-00330-PAE Document317 Filed 08/13/21 Page14of14
Conclusion
For the reasons above and in this Court’s April 16, 2021 Opinion & Order, the Court
DENIES Maxwell’s motion to obtain relief sp
Case 1:20-cr-00330-PAE Document317 Filed 08/13/21 Page11of14
VI. No bill of particulars is warranted
Maxwell moves for a bill of particulars as to counts five and six. Federal Rule of
Criminal Proce
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page9of14
applicable limitations period has not yet run — offenses that by definition are those for which
“other law[s]” of limitation would otherwi
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page6of14
no indication that Maxwell was even a subject of the Florida investigation. The Double Jeopardy
Clause bars only successive prosecution or
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page5of14
case focused on whether prosecutors were required to honor a promise that the court found to be
clear in the absence of a formal plea agre
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page2of14
@ Maxwell moves to dismiss counts five and six on the grounds that prosecuting her on
those counts would violate her rights under the Doub
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page4of14
Court in Commonwealth v. Cosby, No. 39 MAP 2020, 2021 WL 2674380 (Pa. June 30, 2021),
requires dismissal. Neither argument is persuasive.
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page3of14
renewed motion for substantially the same reasons set forth in its April 16 opinion. The Court
will proceed to briefly explain why neither
Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page1of14
USDC SDNY
UNITED STATES DISTRICT COURT srictiniaenis:
SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED
DOC #:
DATE FILED: 8/13/21
Unit
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 26 of 27
To Be Filed Under Seal
to use at a trial, rather than seeking information as part of a criminal investigation or grand jury
proceed
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 27 of 27
To Be Filed Under Seal
Circuit—even before a final order disposing of the intervenors’ appeal—has been critical of that
fact, and h
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 25 of 27
To Be Filed Under Seal
destroy evidence, flee from prosecution, or otherwise seriously jeopardize the Investigation—
that caused th
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 24 of 27
To Be Filed Under Seal
The term “extraordinary circumstances” is not well defined. See Talco Contractors, Inc.,
153 F.R.D. at 511.
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 23 of 27
To Be Filed Under Seal
This decision accords with those of other courts in this Circuit. “Where a protective
order contains express
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 19 of 27
To Be Filed Under Seal
while the Protective Order also had a permanent aspect about it—i.e., it provides for the return or
destruct
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 17 of 27
To Be Filed Under Seal
strong presumption against access to documents . . . we have held more recently in United States
v. Amodeo,
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 14 of 27
To Be Filed Under Seal
Ce On the Current Record, the Court Cannot Find That the Protective Order
Was “Improvidently Granted”
Under M
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 12 of 27
To Be Filed Under Seal
Second, the Government argues that Martindell does not apply when “as here, the
protective order is on its f
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 13 of 27
To Be Filed Under Seal
a grand jury subpoena, with which the party (the defendant) complied. At no point did the
defendant seek rel
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 11 of 27
To Be Filed Under Seal
and that such an order should not be vacated or modified merely to accommodate the
Government’s desire to in
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 10 of 27
To Be Filed Under Seal
need. Here such a showing was amply demonstrated. To have refused access to these records in
the face of a s
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 8 of 27
To Be Filed Under Seal
by motion to quash or modify the subpoena . . . or to seek permissive intervention in the private
action.”) (
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 7 of 27
To Be Filed Under Seal
Order. (Letter from AUSA Alex Rossmiller to the Hon. Robert W. Sweet, dated Feb. 28, 2019
(“Gov’t Letter Br.”
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 6 of 27
To Be Filed Under Seal
Shortly after the oral argument, the Court of Appeals issued an unusual order, giving the
parties to the appe
Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 2 of 27
To Be Filed Under Seal
UNITED STATES DISTRICT COURT ,
SOUTHERN DISTRICT OF NEW YORK ( : O PY
IN RE GRAND JURY SUBPOENA
~
19 Mise.
Case 1:20-cr-00330-PAE Document 311-3 Filed 07/02/21 Page2of3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
IN RE GRAND JURY SUBPOENA : SEALED ORDER
19 Misc. 149
Upon the Affirmation