EFTA00031609.pdf

Type: pdf
Source set: data-set-8
Extracted text

U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Salo ..l. Mao Building 
One Saint Andrew's Plaza 
New York New Tont 10007 
April 30, 2021 
BY ELECTRONIC MAIL 
Mark Manle 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Mr. Manley: 
The Government writes in response to your letter to the Honorable Alison J. Nathan regarding 
your client 
and your request for assurances regarding ensuring your client's anonymity 
in upcoming criminal proceedings, including in documents or information that identifies your client. 
As an initial matter, the Government notes that to date, there have been no filings on the public 
docket in the above-captioned criminal case that name your client. Second, to the extent the 
Government has produced documents with your client's name to the defense pursuant to its disclosure 
obligations in this criminal case, those materials have been designated as confidential and are 
governed by the Protective Order in this case (Dkt. No. 36). Pursuant to the Protective Order, the 
defense is prohibited from filing publicly any confidential information referenced in the discovery 
materials, unless authorized by the Government in writing or by order of the Court. The defense has 
complied with this requirement of the Protective Order and has indicated that it will continue to do 
SO. 
As to the upcoming criminal trial in this matter, the Government notes that it does not intend 
to call your client as a witness at trial. As a courtesy,' we note that your client's name may arise 
As a general matter, the Government is not obligated to provide a detailed preview to the defense, 
or third parties, about how it expects to prove its case at trial. 
EFTA00031609


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during the public testimony of witnesses and may be listed on public exhibits introduced at trial. See 
United States v. Akhavan, 20 Cr. 188 (JSR), 2021 WL 1216909, at *3 (S.D.N.Y. Apr. I, 2021) ("[T]he 
public has a similar right to acces…
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