Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6
COHEN & GRESSER LLP
Mark S. Cohen
+1 (212) 957-7600
[email protected]
Christian R. Everdell
+1 (212) 957-7600
[email protected]
August 10, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
AO Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter motion
seeking the Court’s assistance with two critical issues that greatly impact Ms. Maxwell’s ability
to receive a fair trial on the schedule set by the Court. First, we request that the Court enter an
order directing the government to disclose to defense counsel the identities of the three alleged
victims referenced in the indictment (“Victims 1-3”), subject to the restrictions of the protective
order entered by the Court, so that Ms. Maxwell and defense counsel can meaningfully
investigate the alleged conduct, which is now over 25 years old. Second, we request that the
Court enter an order directing the Bureau of Prisons (“BOP”) to release Ms. Maxwell into the
general population and provide Ms. Maxwell with increased access to the discovery materials
while she is detained so that she can meaningfully participate in the preparation of her defense.
1. Disclosure of Victim Identities
The Court should order the government to disclose the identities of Victims 1-3 to
defense counsel, subject to the restrictions of the protective order, because Ms. Maxwell cannot
prepare for or receive a fair trial without this information. Moreover, the requested disclosure is
authorized under the law in this Circuit, and is narrowly-tailored and reasonable under the
circumstances of this case.
Here, it is clear from the face of the indictment that the government’s case is based on the
accounts of Victims 1-3, the three individuals specifically referenced in the indictment. It is
therefore critical for the defense to know the names of these individuals as soon as possible, so
DOJ-OGR-00001705