EFTA00029966.pdf

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pdf

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data-set-8

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Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1 of 5 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio J. Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
August 13, 2020 
VIA 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. Chislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Judge Nathan: 
The Government respectfully submits this letter in opposition to the defendant's letter of 
August 10, 2020 (the "Defense Letter" or "Def. Ltr."), requesting that the Court order the 
Government to disclose the names of certain Government witnesses 1I months prior to trial, and 
requesting that the Court intervene in the protocols and individualized inmate determinations of 
the Bureau of Prisons. Both applications should be denied. 
A. The Defendant's Demand That the Government Name Certain Trial Witnesses 
For the third time in as many weeks, the defendant and her counsel have applied to the 
Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28) 
(denying the defendant's request that the Court enter an order prohibiting the Government and 
attorneys for non-parties from making extrajudicial statements "concerning this case"); Order 
dated July 30, 2020 (Dkt. 37) (denying the defendant's application for a protective order that would 
allow the defense to publicly name and identify victims). In the defendant's most recent 
application, she asks the Court to order that the Government disclose a partial witness list, in the 
form of identifying certain victims referenced in the Superseding Indictment (the "Indictment"), 
fully 11 months prior to trial. This request is at best premature given that the production of 
discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have 
had no discussions about—let …

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