Case 1:20-cr-00330-PAE Document 218
Cy
HADDON
MORGAN
FOREMAN
April 15, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Filed 04/19/21 Page1of8
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmilaw.com
[email protected]
Re: Response to Government’s April 5, 2021 Letter re. Ms. Maxwell’s Rule 17 Subpoena
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The government’s superficial analysis of a Fed. R. Crim. P. 17 subpoena is neither
accurate nor informative. The collection of various cliché phrases about Rule 17 subpoenas,
selectively gathered from cases inapplicable here, is unpersuasive, and the Court should deny
the requested relief because: (1) the government lacks standing to interfere with subpoenas
issued to the third party respondents; and (2) this intrusion is yet another attempt to infringe
on Ms. Maxwell’s constitutional rights to effective assistance of counsel, a fair trial, and due
process, all in violation of the 5“ and 6" Amendments to the United States Constitution.
I. Background
In February 2016 (and likely at least one other time in the weeks and months that
followed), lawyers representing numerous civil litigants, including then-Plaintiff Virginia
Giuffre, met with the government to foment an indictment of Ms. Maxwell. These lawyers
and their clients sought a tactical advantage in their civil litigations, worth millions of dollars.
This first meeting was followed up by additional communications from these lawyers to the
government. Subsequently, and unknown to Ms. Maxwell, the government brokered a deal
DOJ-OGR-00003853