067.pdf

Type

pdf

Source set

house-oversight-doj

Pages

4

Text status

Searchable text available

OCR confidence

0.9494141291660858

Original source

Extracted text

Case 1:20-cr-00330-AJN Document 67 Filed 10/30/20 Page 1 of 4 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 October 30, 2020 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 submits this letter in response to the defense letter dated October 23, 2020 in the above-referenced case (the “Defense Letter’). For all of its innuendo and accusations, the Defense Letter is at base an effort to preview again motions that the Court has already found to be premature, and to cast the Government’s efforts to be transparent with the Court and the defense in a nefarious and deeply misleading light. The Government writes to correct the inaccuracies in the Defense Letter, to update the Court regarding the status of the Government’s ongoing discovery productions, and to address the defense complaints regarding the Metropolitan Detention Center (“MDC”). 1. The Government Has and Will Continue to Satisfy Its Discovery Obligations The Defense Letter raises numerous accusations, including that the Government has “abandon[ed]” the discovery deadlines in this case. (Def. Ltr. 1). The Government strongly disagrees, and notes that it has produced considerable Rule 16 discovery to the defense, which, to date, consists of more than 350,000 pages. Contrary to the defense’s assertions, that discovery does include both “[c]orroborating [i]nformation” regarding the conduct charged in this case as well as potentially “[e]xculpatory [e]vidence,” (Def. Ltr. 3), and the Government remains available to discuss that material with defense counsel. Moreover, in anticipation of the November 9, 2020 discovery deadline, the Government is preparing to make additional productions, inc…

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