Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page 1of5
COHEN & GRESSER LLP
Mark S. Cohen
+1 (212) 957-7600
[email protected]
Christian R. Everdell
+1 (212) 957-7600
[email protected]
August 17, 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 to reply to
the government’s letter, dated August 13, 2020, responding to Ms. Maxwell’s request that the
Court (i) direct the government to disclose the identities of the three alleged victims referenced
in the indictment, subject to the restrictions of the protective order in this case; and (i1) order the
Bureau of Prisons (“BOP”) to provide Ms. Maxwell with increased access to the discovery
materials (“Government’s Response” or “Gov’t Resp.”) (Dkt. 41).
With regard to the issue of alleged victims’ identities, the government concedes, as it
must, that this Court has the authority and discretion to order the relief sought, but claims that
Ms. Maxwell’s application should be denied as untimely and without merit. (Gov’t Resp. at 2-
4). Instead, the government asserts that the appropriate and timely way for Ms. Maxwell to seek
confirmation of their identities is through a request for a bill of particulars, which should be filed
in December 2020. (/d. at 3). The government then notes that it would oppose such a motion,
which it claims should also be denied. (/d.). The government concludes that it will finally
provide confirmation of their identities in the 3500 material and a witness list to be provided
shortly before trial. (/d. at 4).
The upshot of this is clear: in the government’s view, Ms. Maxwell should not know the
identity of the three witnesses referenced in the indictment until at best just before trial, and
should have to spend the next eleven months (or longer) trying to conduct a defense
investigation, in a case in which she is presumed innocent, without having this information.
This information is critical to conducting a meaningful defense investigation, given that the
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