Case 1:20-cr-00330-PAE
Cy
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
Document 705
Filed 07/12/22 Page1of12
Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmflaw.com
[email protected]
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 (AJN)
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
DOJ-OGR-00011241