Document 10

Case 1:19-cr-00490-RMB Document 10 Filed 07/12/19 Page 1 of 2 Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 11, 2019 MEMO ENDORSED P 2 VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's motion for leave to file a supplemental financial disclosure under seal (the "Sealing Motion") in connection with his motion for pretrial release (the "Bail Motion"). The Government takes no position on the defendant's application, but notes that as of this filing the Government still has not yet received any financial disclosure or information from the defense in connection with the defendant's application for bail. It is now more than three days following the defendant's initial presentment, more than seven hours after the defendant's deadline to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no reason that the defendant need have waited until this evening to submit his Sealing Motion, and the Government cannot meaningfully respond to a Bail Motion that contains no material financial information, either under seal or otherwise. Accordingly, the Government respectfully requests that its deadline to respond to the defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of any financial information upon which he intends to rely in connection with the Motion. Should USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 7/12/19 DOJ-OGR-00000327 --- PAGE BREAK --- Case 19-2221, Document 10, 08/05/2019, 2624204, Page1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT CRIMINAL APPEAL TRANSCRIPT INFORMATION - FORM B TO BE COMPLETED BY ATTORNEY: CASE NAME: United States of America v. Jeffery Epstein DOCKET NUMBER: 19-2221 COUNSEL'S NAME: Reid Weingarten COUNSEL'S ADDRESS: Steptoe & Johnson LLP, 1114 Avenue of the Americas, New York, NY 10036 COUNSEL'S PHONE: 212-506-3900 QUESTIONNAIRE I am ordering a transcript. I am not ordering a transcript. Reason: Daily copy available Other (attach explanation) TRANSCRIPT ORDER Prepare transcript of Pre-trial proceedings: (Description & Dates) Trial: (Description & Dates) Sentencing: (Description & Dates) Post-trial proceedings: (Description & Dates) I, , hereby certify that I will make satisfactory arrangements with the court reporter for payment of the costs of the transcript in accordance with FRAP 10(b). Method of payment: Funds CJA Form 24 Counsel's Signature Date TO BE COMPLETED BY COURT REPORTER AND FORWARDED TO COURT OF APPEALS: ACKNOWLEDGMENT Date order received: Estimated Number of Pages: Court Reporter's Signature Date Attorney(s): Send completed form to the U.S. District Court as that court may require and send copies to the Court of Appeals, U.S. Attorney's Office, and Court Reporter. Court Reporter(s): Send completed acknowledgement to the Court of Appeals Clerk. DOJ-OGR-00000829 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 10 Filed 07/07/20 Page USDCSDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 7/7/2020 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, -v- Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) ORDER ALISON J. NATHAN, District Judge: An arraignment, initial conference, and bail hearing in this matter is hereby scheduled to occur as a remote video/teleconference using an internet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers will email counsel with further information on how to access the video conference. To optimize the quality of the video feed, only the Court, the Defendant, defense counsel, and counsel for the Government will appear by video for the proceeding; all others may access the audio of the public proceeding by telephone. Due to the limited capacity of the internet platform system, only one attorney per party may participate by video. Co-counsel, members of the press, and the public may access the audio feed of the proceeding by calling a dial-in number, which the Court will provide in advance of the proceeding by subsequent order. Given the high degree of public interest in this case, a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements, seating will be extremely limited; when capacity is reached no additional persons will be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to DOJ-OGR-00001540 --- PAGE BREAK --- Case 20-3061, Document 10, 09/10/2020, 2928093, Page1 of 1 NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL Short Title: United States v. Maxwell Docket No.: 20-3061 Substitute, Additional, or Amicus Counsel's Contact Information is as follows: Name: Maurene Comey Firm: United States Attorney's Office for the Southern District of New York Address: One St. Andrew's Plaza Telephone: (212) 637-2324 Fax: (212) 637-2387 E-mail: maurene.comey@usdoj.gov Appearance for: United States of America/Appellee (party/designation) Select One: Substitute counsel (replacing lead counsel: ____________________ (name/firm) Substitute counsel (replacing other counsel: ____________________ (name/firm) Additional counsel (co-counsel with: Won S. Shin/U.S. Attorney's Office for the Southern District of New York) (name/firm) Amicus (in support of : ____________________ (party/designation) CERTIFICATION I certify that: I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on N/A OR I applied for admission on ____________________. Signature of Counsel: /s/Maurene Comey Type or Print Name: Maurene Comey DOJ-OGR-00019280 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 10 Filed 07/07/20 Page 2 of 4 arriving at the courthouse. All visitors must also have their temperature taken when they arrive at the courthouse. Please see the instructions, attached. Completing the questionnaire ahead of time will save time and effort upon entry. Only persons who meet the entry requirements established by the questionnaire and whose temperatures are below 100.4 degrees will be allowed to enter the courthouse. Face coverings that cover the nose and mouth must be worn at all times. Anyone who fails to comply with the COVID-19 protocols that have been adopted by the Court will be required to leave the courthouse. There are no exceptions. As discussed in the Court's previous order, defense counsel shall, if possible, discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form (either personally or, in accordance with Standing Order 20-MC-174 of March 27, 2020, by defense counsel), defense counsel shall file the executed form at least 24 hours prior to the proceeding. In the event the Defendant consents, but counsel is unable to obtain or affix the Defendant's signature on the form, the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendant's signature to the form. Pursuant to 18 U.S.C. § 3771(c)(1), the Government must "make their best efforts to see that crime victims are notified of, and accorded, the rights" provided to them in that section. This includes "[t]he right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime or of any release . . . of the accused" and "[t]he right to be reasonably heard at any public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The Court will inquire with the Government as to the extent of those efforts. So that appropriate logistical arrangements can be made, the Government shall inform the Court by DOJ-OGR-00001541 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 10 Filed 07/07/20 Page 3 of 4 email within 24 hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial. Finally, the time between the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district. See 18 U.S.C. § 3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from today through July 14, 2020. Due to the logistical issues involved in conducting a remote proceeding, the Court finds "that the ends of justice served by [this exclusion] outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C. § 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss a potential protective order, which will facilitate the timely production of discovery in a manner protective of the rights of third parties. See Dkt. No. 5. SO ORDERED. Dated: July 7, 2020 New York, New York ALISON J. NATHAN United States District Judge DOJ-OGR-00001542 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 10 Filed 07/07/20 Page 4 of 4 All members of the public, including attorneys, appearing at a Southern District of New York courthouse must complete a questionnaire and have their temperature taken before being allowed entry into that courthouse. On the day you are due to arrive at the courthouse, click on the following weblink, or scan the following QR code with a mobile device camera to begin the enrollment process. Follow the instructions and fill out the questionnaire. If your answers meet the requirements for entry, you will be sent a QR code to be used at the SDNY entry device at the courthouse entrance. https://app.certify.me/SDNYPublic Note: If you do not have a mobile phone or mobile phone number, you must complete the questionnaire and temperature screening at an entry device at the courthouse. DOJ-OGR-00001543