703.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 7
- Text status
- Searchable text available
- OCR confidence
- 0.9364664804765735
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 703 Filed 07/12/22 Pagelof7 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 December 12, 2021 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, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter moving to preclude one exhibit which the defendant produced in Rule 16 discovery Friday night. Following the close of the Government’s case in chief, the defendant produced her witness list and Rule 26.2 disclosures. In addition, the defendant attached two new documents as Rule 16 discovery: a sale agreement for the defendant’s London home at 44 Kinnerton Street (attached as Exhibit A) and a judicial opinion in United States v. Epstein, 96 Civ. 8307 (DC) (S.D.N.Y. Mar. 31, 1998). The Government seeks to preclude the sale agreement under Rule 16.! The sale agreement should have been disclosed on November 8, 2021, the Court’s deadline ' Although the judicial opinion does not appear to be admissible, the Government plans to confer with the defense on that document. 1 DOJ-OGR-00011206
Case 1:20-cr-00330-PAE Document 703 Filed 07/12/22 Page2of7 for defense production of Rule 16 materials. The Government is prejudiced by the defendant’s decision to delay production until after the close of the Government’s case, and the defendant should therefore be precluded from offering the agreement in her case-in-chief. And in any event, the agreement should be excluded under Rule 403. I. Applicable Law Pursuant to Federal Rule of Criminal Procedure 16(b)(1)(A), if a defendant “requests disclosure under Rule 16(a)(1)(E) and the government complies,” then the defendant must permit the Government to inspect any documents in the defendant’s “possession, custody, or control…
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