455.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 3
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- Searchable text available
- OCR confidence
- 0.9136137518811939
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Pagelof3 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 November 12, 2021 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 seeking clarification on two items from the November 1, 2021 pretrial conference. First, when describing the defendant’s ability to cross-examine witnesses who will be testifying under pseudonyms, the Court explained that: All lines of inquiry the defense outlined in its response are available without disclosing specific names of employers or other specifically identifying information. For example, the defense can probe the genre, nature, and trajectories of witnesses' careers without eliciting the specific employer name, but the defense's cross-examination should not include specifically identifying information, and counsel must act responsibly doing so. (11/01/21 Tr. at 11:20-12:2). The Government seeks clarification before trial about the line between permissible and impermissible cross-examination [i DOJ-OGR-00006950
Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page2of3 Page 2 a! PO (11/01/21 Tr. at 10:8-11). That information has no re But it creates significant risk of identifying the relevant Minor Victims and witnesses by narrowing the field of people whose careers match the description elicited by the defense at the times elicited by the defense, and in combination with the other information about them that will be available at trial. Second, the Government seeks clarification that the Court’s November 1, 2021 order permitting witnesses to testify using pseudonyms or first names includes an order barring courtroom sketch artists from …
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