EFTA00014671.pdf

Type: pdf
Source set: data-set-8

Extracted text

HADDON
MORGAN
FOREMAN
May 12, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Haddon, Morgan and Foreman. r.c
Jeffrey Paglluca
Denver. Colorado 80203
Re:
Response to Government Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P.
17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Judge Nathan,
On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3)
subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers
working with the government on behalf of alleged (now-adult) witnesses. In her ex-parte
application, Ms. Maxwell provided reasons for requesting certain items of evidence, including
that the government either failed to secure the evidence or refused to produce it to Ms. Maxwell;
she also disclosed theories related to her defense, strategy, and work product.
After considering the application and BSF's response, the Court invited comment from
the government regarding subpoenaed items 9 (a journal), 10 (boots), and 11(photographs).
Specifically, the Court directed the government "to notify the Court of its views as to Requests 9
through 11." Dkt. 252.
The government's position is consistent with its general approach to evidence in this case
which is to blindly accept information it considers unfavorable to Ms. Maxwell, begrudgingly
EFTA00014671

The Honorable Alison J. Nathan
May 12, 2021
Page 2
produce Brady material with various disclaimers such as "although the government is not
obligated to do so" (Dkt. 269 pp. 8, 9), and obfuscate the importance of legitimate defense
requests for discovery. The government repeatedly demonstrates that it views this process not as
a search for the truth, but for a conviction at any cost, including the truth.
Request 9, The Journal
Accuser-2 has been represented by BSF since approximately 2016. She sued Ms.
Maxwell an…

Open in the interactive archive →