EFTA00029590.pdf

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Source set: data-set-8

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Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 1 of 5
HADDON
MORGAN
FOREMAN
August 30, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Haddon, Morgan and Foreman. P.0
Jeffrey Fag!loco
www.hmflow.corn
[email protected]
Re:
Response to Government Letter dated August 18, 2021, Dkt. 320, United States v.
Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Judge Nathan,
I write in response to the government's letter dated August 18, 2021, Dkt. 320, which
raises two issues.'
Identities of Co-Conspirators
The government first attempts to walk back its multiple concessions regarding disclosure
of the identities of the unnamed co-conspirators alleged in the S2 indictment.
As this Court noted, Ms. Maxwell has on at least two occasions requested such
disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered
disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the
government finally object. The government's objection comes too late.
' As directed by the Court, on August 24 the parties conferred about the government's
letter, but they were unable to reach an agreement on the government's requests for
reconsideration.
EFTA00029590

Case 1:20-cr-00330-AJN Document 331 Filed 08/30/21 Page 2 of 5
The Honorable Alison J. Nathan
August 30, 2021
Page 2
The government's objection is, in substance, a motion to reconsider. "There is `no
specific rule, either in the Federal Rules of Criminal Procedure or in this district's local criminal
rules that provide for reconsideration of a ruling in a criminal matter.' United States v.
Okparaeke, No. 17-CR-225 (NSR), 2019 WL 4233427, at *2 (S.D.N.Y. Sept. 6, 2019) (quoting
United States v. Cartagena, No. 10 Cr. 222-2, 2012 WL 2958175, at *1 (S.D.N.Y. July 20,
2012)). Even so, courts have discretion to reconsider prior rulings in criminal cases whe…

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