Epstein Project

EFTA00027169.pdf

Type
pdf
Source set
data-set-8

Original source

Extracted text

Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 1 of 5 
HADDON 
MORGAN 
FOREMAN 
April 22, 2021 
The Hon. Alison J. Nathan 
United States District Court Judge 
Southern District of New York 
40 Foley Square 
New York, NY 10007 
Haddon. Morgan and Foreman, P.0 
Jeffrey S. Pagliuca 
150 East I Oth Avenue 
Denver, Colorado 80203 
PH 303.831.7364 EX 303.832.2628 
wvv.hmftaw.com 
jpogliucatihmflaw.com 
Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) 
Response to Dkt. No. 227, Government's April 21.2021 Letter re Ms. Maxwell's 
Motions to Suppress 
Dear Judge Nathan: 
We write in response to the government's letter about Ms. Maxwell's pending motions 
to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court's order stating 
an intent to defer resolution of those motions and that request until after the trial on the non-
perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial 
process and the desire to efficiently resolve the pending disputes, we do not agree that the 
government's letter provides an adequate basis to defer resolution of Ms. Maxwell's motions. 
We understand the Court's desire to maintain the status quo relating to the defense motions, 
but the government's response gives Ms. Maxwell no confidence that the government shares 
this understanding. Indeed, the government's vague assurances are insufficient to safeguard 
Ms. Maxwell's constitutional rights, to guarantee the government will not benefit from its 
unconstitutional conduct, and to ensure that Ms. Maxwell's is not deprived of due process 
through the introduction and use of evidence that itself was obtained in violation of due 
process. 
EFTA00027169


Case 1:20-cr-00330-AJN Document 234 Filed 04/22/21 Page 2 of 5 
The Hon. Alison J. Nathan 
April 22, 2021 
Page 2 
The government says that this Court need not resolve Ms. Maxwell's motions to 
suppress or hold an evidentiary hearing before the trial on the non-perjury counts bec…

Open in the interactive archive →