Document 22-1426, Document 1-2

Case 22-1426, Document 1-2, 07/08/2022, 33444177, Page7 of 91 | 07/06/2020 | 6 | Rule 5(c)(3) Documents Received as to Ghislaine Maxwell from the United States District Court - District of New Hampshire. (jm) (Entered: 07/06/2020) | 07/06/2020 | 7 | ORDER as to Ghislaine Maxwell. This matter has been assigned to me for all purposes. In its July 5, 2020 letter, the Government on behalf of the parties requested that the Court schedule an arraignment, initial appearance, and bail hearing in this matter in the afternoon of Friday, July 10. See Dkt. No. 5. In light of the COVID public health crisis, there are significant safety issues related to in-court proceedings. If the Defendant is willing to waive her physical presence, this proceeding will be conducted remotely. To that end, defense counsel should confer with the Defendant regarding waiving her physical presence. If the Defendant wishes to waive her physical presence for this proceeding, she and her counsel should sign the attached form in advance of the proceeding if feasible.If this proceeding is to be conducted remotely, there are protocols at the Metropolitan Detention Center that limit the times at which the Defendant could be produced so that she could appear by video. In the next week, the Defendant could be produced by video at either 9:00 a.m. on July 9, 2020 or sometime during the morning of July 14, 2020. Counsel are hereby ordered to meet and confer regarding scheduling for this initial proceeding in light of these constraints. If counsel does anticipate proceeding remotely, by 9:00 p.m. tonight, counsel should file a joint letter proposing a date and time for the proceeding consistent with this scheduling information, as well as a revised briefing schedule for the Defendant's bail application.SO ORDERED. (Signed by Judge Alison J. Nathan on 7/6/2020)(jbo) (Entered: 07/06/2020) | 07/06/2020 | 8 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Mark S. Cohen dated July 6, 2020 re: Scheduling (Cohen, Mark) (Entered: 07/06/2020) | 07/07/2020 | 9 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Alex Rossmiller dated July 7, 2020 re: scheduling Document filed by USA. (Rossmiller, Alex) (Entered: 07/07/2020) | 07/07/2020 | 10 | ORDER as to Ghislaine Maxwell. 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 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, DOJ-OGR-00020393 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page15 of 91 | 11/18/2020 | 73 | MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 60 Letter filed by USA as to Ghislaine Maxwell re: The Government respectfully requests that the Court approve the Government's request to delay disclosure of these Materials...ENDORSEMENT...There is no dispute that the materials referenced in the Government's letter will be turned over to the defense. The Government has indicated that it will do so. The only dispute, then, relates to the timing of such disclosure. See Dkt. Nos. 64, 65. Because the Government has articulated plausible reasons for some delay of disclosure, see Dkt. No. 65 at 4, the Court grants the Government's request to delay disclosure. However, the Governments proposal to delay disclosure until 8 weeks in advance of trial is insufficient. In order to ensure that the defense can adequately prepare for trial, the Government shall produce the referenced materials, which are not voluminous, to the defense by March 12, 2021. Disclosure of the materials will of course be subject to the protective order entered by the Court, see Dkt. No. 36. (Government Responses due by 3/12/2021) (Signed by Judge Alison J. Nathan on 11/18/20)(jw) (Entered: 11/18/2020) | 11/23/2020 | 74 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated November 23, 2020 re: Update Regarding Conditions of Confinement Document filed by USA. (Comey, Maurene) (Entered: 11/23/2020) | 11/24/2020 | 75 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report (Sternheim, Bobbi) (Entered: 11/24/2020) | 11/24/2020 | 76 | MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 75 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 11/24/2020 re: Response to 90-day MDC conditions report. ENDORSEMENT: The parties are hereby ORDERED to meet and confer regarding Defendant's request that Warden Heriberto Tellez directly address Defendant's concerns regarding the conditions of her detention. The parties shall jointly submit a status update within one week of this Order. (Signed by Judge Alison J. Nathan on 11/24/2020) (ap) (Entered: 11/24/2020) | 12/01/2020 | 77 | ORDER as to Ghislaine Maxwell. On November 25, 2020, the Defendant filed a letter request under seal. On November 30, 2020, she filed a second letter request in which she proposed redactions on both letters. The Government is hereby ORDERED to respond to the Defendant's November 25, 2020 letter request and to the request for proposed redactions by no later than December 2, 2020. The letters shall be temporarily sealed while the Court resolves the redaction request. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/1/2020)(bw) (Entered: 12/01/2020) | 12/01/2020 | 78 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of Confinement Document filed by USA. (Pomerantz, Lara) (Entered: 12/01/2020) | 12/02/2020 | 79 | MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 78 LETTER by USA addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 1, 2020 re: Joint Letter regarding Conditions of Confinement. ENDORSEMENT: MDC legal counsel shall submit their letter to the Court by December 4, 2020. Upon review of that letter, the Court will determine whether any additional information is required, either orally or in writing. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/2/2020)(bw) (Entered: 12/02/2020) | 12/02/2020 | 80 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, and Lara Pomerantz dated December 2, 2020 re: Defense Requests for Sealing Document filed by USA. (Comey, Maurene) (Entered: 12/02/2020) | 12/03/2020 | 81 | ORDER as to Ghislaine Maxwell. On November 25, 2020, counsel for Defendant Ghislaine Maxwell filed a letter request seeking an in camera conference for the presentation of a renewed motion for release on bail and a request to seal the November 25, 2020 letter in its entirety. The Court required justification for the sealing request. On November 30, 2020, the defense counsel filed a second letter no longer fully pressing the unsupported request to file the letter entirely under seal and DOJ-OGR-00020401 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page20 of 91 | Date | Doc # | Description | |------------|-------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------| | 12/31/2020 | 107 | LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31, 2020 re: Extension of Time. Document filed by Ghislaine Maxwell. (Everdell, Christian) (Entered: 12/31/2020) | | 01/05/2021 | 108 | MEMO ENDORSEMENT as to Ghislaine Maxwell (1) on 107 LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated December 31, 2020 re: Extension of Time. ENDORSEMENT: SO ORDERED. (Signed by Judge Alison J. Nathan on 1/5/2021) (ap) (Entered: 01/05/2021) | | 01/05/2021 | | Set/Reset Deadlines as to Ghislaine Maxwell: Motions due by 1/25/2021. Responses due by 2/26/2021. Replies due by 3/5/2021. (ap) (Entered: 01/05/2021) | | 01/08/2021 | 109 | LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 8, 2021 re: Extension of Time to File Notice of Appeal. Document filed by Ghislaine Maxwell. (Everdell, Christian) (Entered: 01/08/2021) | | 01/11/2021 | 110 | SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021) | | 01/11/2021 | 111 | SEALED DOCUMENT placed in vault. (jus) (Entered: 01/11/2021) | | 01/11/2021 | 112 | MEMO ENDORSEMENT as to Ghislaine Maxwell (1) denying 109 LETTER MOTION addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 8, 2021 re: Extension of Time to File Notice of Appeal. ENDORSEMENT: The request is denied. Good cause for an extension of time to file a notice of appeal has not been provided. SO ORDERED. (Signed by Judge Alison J. Nathan on 1/11/2021) (lnl) (Entered: 01/11/2021) | | 01/11/2021 | 113 | NOTICE OF APPEAL by Ghislaine Maxwell from 104 Order. (nd) (Entered: 01/12/2021) | | 01/11/2021 | | Appeal Remark as to re: 113 Notice of Appeal by Ghislaine Maxwell. $505.00 Appeal filing fee due. (nd) (Entered: 01/12/2021) | | 01/12/2021 | | Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine Maxwell to US Court of Appeals re: 113 Notice of Appeal. (nd) (Entered: 01/12/2021) | | 01/12/2021 | | Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal Electronic Files as to Ghislaine Maxwell re: 113 Notice of Appeal were transmitted to the U.S. Court of Appeals. (nd) (Entered: 01/12/2021) | | 01/13/2021 | 114 | INTERNET CITATION NOTE as to Ghislaine Maxwell: Material from decision with Internet citation re: 106 Memorandum & Opinion. (sjo) (Entered: 01/13/2021) | | 01/14/2021 | 115 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 14, 2021 re: Laptop Access (Everdell, Christian) (Entered: 01/14/2021) | | 01/15/2021 | 116 | MEMO ENDORSEMENT as to Ghislaine Maxwell on 115 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 14, 2021 re: Laptop Access. ENDORSEMENT: The unobjected-to request is GRANTED. The Bureau of Prisons is ORDERED to give the Defendant access to the laptop computer on weekends and holidays during the hours that she is permitted to review discovery. SO ORDERED. (Signed by Judge Alison J. Nathan on 1/15/2021) (lnl) (Entered: 01/15/2021) | | 01/15/2021 | | USCA Case Number 21-0058 from the U.S. Court of Appeals, 2nd Circ. as to Ghislaine Maxwell, assigned to 113 Notice of Appeal filed by Ghislaine Maxwell. (nd) (Entered: 01/15/2021) | | 01/15/2021 | | USCA Appeal Fees received $505.00, receipt number 465401271727 as to Ghislaine Maxwell on 1/15/2021 re: 113 Notice of Appeal filed by Ghislaine Maxwell. (nd) (Entered: 01/15/2021) | | 01/25/2021 | 117 | ORDER as to Ghislaine Maxwell: On January 25, 2021, the Court received by email the attached letter from the Bureau of Prisons ("BOP"). In the letter, the BOP requests that the Court vacate its January 15, 2021 Order, Dkt. No. 116, which directed the BOP to give the Defendant access to her Government provided laptop computer on weekends and holidays during the hours that she is permitted to review discovery. The Defendant and the Government may respond to the BOP's letter within one week of | DOJ-OGR-00020406 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page32 of 91 the grounds that it was returned by a grand jury sitting at the White Plains courthouse (Dkt. No. 125) is DENIED as moot. SO ORDERED. (Signed by Judge Alison J. Nathan on 4/21/21)(jbo) (Entered: 04/21/2021) 04/21/2021 229 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 21, 2021 re: Proposed Pretrial Schedule Document filed by USA. (Comey, Maurene) (Entered: 04/21/2021) 04/21/2021 230 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated April 21, 2021 re: Proposed Pretrial Schedule (Everdell, Christian) (Entered: 04/21/2021) 04/21/2021 231 ORDER as to Ghislaine Maxwell: The Court will schedule a trial date for the severed perjury counts after trial of the non-perjury counts is completed. Given that and in light of the representations in the Government's April 21, 2021 letter, see Dkt. No. 227, the Court intends to defer resolution of the pending motions to suppress (including resolution of the request for an evidentiary hearing) until after the trial on the non-perjury counts. If either side objects, counsel shall state the basis for any objection on or before by 5pm on Thursday, April 22, 2021.SO ORDERED. (Signed by Judge Alison J. Nathan on 4/21/2021) (lml) (Entered: 04/22/2021) 04/22/2021 232 MEMO ENDORSEMENT as to Ghislaine Maxwell on 222 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 20, 2021 re: Redactions to Defense Reply Briefs and Exhibits. ENDORSEMENT: The Court grants the Government's proposed redaction and sealing requests. This conclusion is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are "judicial documents;" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 11920. The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. In balancing competing considerations against the presumption of access, however, the Court finds that the specific arguments the Government has put forward in this letter, including the need to protect the privacy interests of third parties and alleged victims, favor the narrowly tailored redactions. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). The Government's letter does not discuss Exhibit L of Reply Brief 6. By April 23, 2021, the parties shall either propose redactions to Exhibit L of Reply Brief 6, which was originally filed under seal, or they shall indicate to the Court that they seek no redactions and file it on ECF. SO ORDERED. (Signed by Judge Alison J. Nathan on 4/22/2021) (lml) (Entered: 04/22/2021) 04/22/2021 233 LETTER by Boies Schiller Flexner LLP as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sigrid McCawley dated 04-22-2021 re: Request to Bring Electronic Devices Document filed by Boies Schiller Flexner LLP. (Attachments: # 1 Exhibit Electronic Device Form)(McCawley, Sigrid) (Entered: 04/22/2021) 04/22/2021 234 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated April 22, 2021 re: Response to Dkt. No. 227, Governments April 21, 2021 Letter re Ms. Maxwells Motions to Suppress (Pagliuca, Jeffrey) (Entered: 04/22/2021) 04/22/2021 235 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 22, 2021 re: Response to Defense Request for Adjournment Document filed by USA. (Comey, Maurene) (Entered: 04/22/2021) 04/22/2021 236 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 22, 2021 re: Response to the Court's April 22, 2021 Order Document filed by USA. (Pomerantz, Lara) (Entered: 04/22/2021) 04/22/2021 237 MEMO ENDORSEMENT as to Ghislaine Maxwell on 233 LETTER by Boies Schiller Flexner LLP as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sigrid McCawley dated 04-22-2021 re: Request to Bring Electronic Devices Document. DOJ-OGR-00020418 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page38 of 91 | 05/07/2021 | 273 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated May 7, 2021 re: Cover Letter for Omnibus Memorandum in Support of the Defendant's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment (Everdell, Christian) (Entered: 05/07/2021) | 05/10/2021 | 274 | MEMO ENDORSEMENT as to Ghislaine Maxwell on 273 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated May 7, 2021 re: Cover Letter for Omnibus Memorandum in Support of the Defendant's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment. ENDORSEMENT: The Government is hereby ORDERED to propose and justify any redactions on May 12, 2021. SO ORDERED. (Signed by Judge Alison J. Nathan on 5/10/2021) (lnl) (Entered: 05/10/2021) | 05/10/2021 | 275 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated May 10, 2021 re: Proposed Trial Date Document filed by USA. (Pomerantz, Lara) (Entered: 05/10/2021) | 05/11/2021 | 276 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 05/10/2021 re: Request for November 8th trial start date (Sternheim, Bobbi) (Entered: 05/11/2021) | 05/11/2021 | 277 | ORDER as to Ghislaine Maxwell: The Court has considered the parties' proposals regarding the commencement of trial. Dkt. Nos. 275, 276. For the reasons stated in the Government's letter, the Court will request November 29, 2021 from the Clerk's Office as the trial start date that is the date (pending approval from the Clerk's Office consistent with the SDNY COVID protocols) that opening statements will be made to the jury. However, the Court will also request from the Clerk's Office that jury selection occur during the week of November 15. Counsel shall plan accordingly. The Court grants the Government's motion to exclude time until November 29, 2021. The Court finds that the ends of justice served by granting an exclusion from speedy trial computations for the period from today's date through November 29, 2021, outweigh the interests of the public and the Defendant in a speedy trial, because this time is necessary to permit the defense to continue to review discovery and other materials in light of the superseding indictment; to permit the parties to prepare and file motions in limine; to permit the parties to make and review additional pretrial disclosures; and to allow adequate time for the parties to prepare for trial. Time is therefore excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A), until November 29, 2021. In order to ensure that there is no delay in the commencement of trial, the Court will adjust the current pre-trial schedule. So that the Court can resolve motions in limine in advance of the November 29th trial commencement date, any such motions shall be fully briefed no later than four weeks in advance of the anticipated trial commencement date of November 29. The parties shall meet and confer to propose adjustments to other pre-trial disclosures accordingly. The parties are hereby ORDERED to meet and confer for at least 30 minutes by phone regarding the overall pretrial disclosure schedule and submit a joint letter by May 14, 2021. The Court will accept only a joint letter with a joint proposal or with each sides views briefly stated. The letter must attest to the meet and confer. Any separately filed letters will be struck. SO ORDERED. (Time excluded from 5/11/2021 until 11/29/2021) (Signed by Judge Alison J. Nathan on 5/11/2021) (lnl) (Entered: 05/11/2021) | 05/12/2021 | 278 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated May 12, 2021 re: Proposed Redactions to Defendant's Supplemental Pre-Trial Motion Document filed by USA. (Pomerantz, Lara) (Entered: 05/12/2021) | 05/13/2021 | 279 | ORDER as to Ghislaine Maxwell: On May 12, 2021, the Defendant submitted a response to the Government's May 4 and May 6 letters. See Dkt. Nos. 269, 271. She submitted it under temporary seal, though she noted that she is willing to file the response and its corresponding exhibits on the public docket. The Government is hereby ORDERED to notify the Court by May 14, 2021 whether it requests that any part of the Defendants submission be redacted or filed under seal; any such request must be justified by reference to the test articulated in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). SO ORDERED. (Signed by Judge Alison J. Nathan on 5/13/2021) (lnl) (Entered: 05/13/2021) DOJ-OGR-00020424 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page52 of 91 | Date | Number | Description | --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page63 of 91 | 11/15/2021 | Terminate Deadlines and Hearings as to Ghislaine Maxwell: (jw) (Entered: 12/09/2021) | 11/16/2021 | Minute Entry for proceedings held before Judge Alison J. Nathan: Voir Dire held on 11/16/2021 as to Ghislaine Maxwell. Defendant Ghislaine Maxwell present with attorney Bobbi Sternheim, Jeff Pagliuca, Christian Everdell, Renato Stabile. AUSAs Lara Pomerantz, Maurene Comey, Alison Moe and Andrew Rohrbach for the government. Court Reporters Eve Giniger and Khris Sellin. Jury selection began. Jury selection adjourned to Wednesday, November 17, 2021 at 8:30 AM. See transcript. (jbo) (Entered: 11/19/2021) | 11/17/2021 | Minute Entry for proceedings held before Judge Alison J. Nathan: (Jury Selection) Jury Trial as to Ghislaine Maxwell held on 11/17/2021. Defendant Ghislaine Maxwell present with attorney Bobbi Sternheim, Jeff Pagliuca, Christian Everdell, Laura Menninger and Renato Stabile. AUSAs Lara Pomerantz, Maurene Comey, and Alison Moe for the government. Court Reporters Eve Giniger and Khris Sellin. Jury selection held. Jury selection adjourned to Thursday, November 18, 2021 at 8:30 AM. See transcript. (jbo) (Entered: 11/19/2021) | 11/18/2021 | 470 | LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated November 18, 2021 re: Courtroom sketch artists Document filed by USA. (Attachments: # 1 Text of Proposed Order Proposed Order)(Rohrbach, Andrew) (Entered: 11/18/2021) | 11/18/2021 | 471 | ORDER as to Ghislaine Maxwell: IT HEREBY IS ORDERED: 1. That courtroom sketch artists whether in the courtroom or overflow rooms may not draw exact likenesses of the Protected Witnesses; and 2. For avoidance of doubt, courtroom sketch artists may confer with the Court or counsel for either party to determine whether a witness is a Protected Witness. SO ORDERED. (Signed by Judge Alison J. Nathan on 11/18/2021) (lnl) (Entered: 11/18/2021) | 11/18/2021 | | Minute Entry for proceedings held before Judge Alison J. Nathan: (Jury Selection) Jury Trial as to Ghislaine Maxwell held on 11/18/2021. Defendant Ghislaine Maxwell present with attorney Bobbi Sternheim, Jeff Pagliuca, Christian Everdell, Laura Menninger and Renato Stabile. AUSAs Lara Pomerantz, Maurene Comey, and Alison Moe for the government. Court Reporters Eve Giniger and Khris Sellin. Jury selection held. Jury selection adjourned until Monday, November 29, 2021 at 9:00 AM. See transcript. (jbo) (Entered: 11/19/2021) | 11/19/2021 | 472 | ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Patrick J. Smith dated 11/18/21 re: We respectfully request that the Court approve Jordana H. Feldman being added to the ECF docket in this case as a movant....ENDORSEMENT: The Clerk of Court is respectfully directed to add Jordana H. Feldman to the ECF docket in this case as a "movant". SO ORDERED. (Signed by Judge Alison J. Nathan on 11/19/21)(jw) (Entered: 11/19/2021) | 11/19/2021 | 473 | ORDER as to Ghislaine Maxwell. The Court is in receipt of the Government's letter motion to quash the Defendants Rule 17(c)(3) subpoena. That motion has been filed temporarily under seal to allow the parties the opportunity to propose limited redactions. The parties are hereby ORDERED to file any proposed redactions on the public docket on or before November 22, 2021, and to justify any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) (Entered: 11/19/2021) | 11/19/2021 | 474 | ORDER as to Ghislaine Maxwell. The Court is in receipt of the Government's letter motion dated November 18, 2021. That motion has been filed temporarily under seal to allow the parties the opportunity to propose limited redactions. Defendant is hereby ORDERED to file a response on or before November 20, 2021. The parties are FURTHER ORDERED to file any proposed redactions to the motion papers on the public docket on or before November 22, 2021, justifying any requested redactions by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (Defendant Responses due by 11/20/2021) (Signed by Judge Alison J. Nathan on 11/19/21)(jw) (Entered: 11/19/2021) DOJ-OGR-00020449 --- PAGE BREAK --- Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page73 of 91 (Rohrbach, Andrew) (Entered: 12/12/2021) 12/12/2021 540 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 12/12/2021 re: Order of Defense Witnesses (Sternheim, Bobbi) (Entered: 12/12/2021) 12/13/2021 541 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated December 13, 2021 re: Privilege stipulation Document filed by USA. (Rohrbach, Andrew) (Entered: 12/13/2021) 12/14/2021 542 ORDER as to Ghislaine Maxwell. The Court is in receipt of the Defense's letter dated December 13, 2021, regarding anticipated witnesses. The Government is ORDERED to submit a response no later than today, December 14, 2021, at 10:00 p.m. The Defense is FURTHER ORDERED to provide a copy of its anticipated witness order to the Court no later than today, December 14, 2021, at 12:00 p.m. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/14/2021)(bw) (Entered: 12/14/2021) 12/14/2021 543 SEALED DOCUMENT placed in vault. (jus) (Entered: 12/14/2021) 12/14/2021 544 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated December 13, 2021 re: Jack Scarola, Brad Edwards and Robert Glassman (Attachments: # 1 Exhibit 1 (Filed Under Seal))(Pagliuca, Jeffrey) (Entered: 12/15/2021) 12/15/2021 545 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated December 14, 2021 re: Testimony from Victim Counsel Document filed by USA. (Rohrbach, Andrew) (Entered: 12/15/2021) 12/15/2021 546 LETTER MOTION addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated December 15, 2021 re: Proposed redactions to Privilege Letters. Document filed by USA as to Ghislaine Maxwell. (Rohrbach, Andrew) (Entered: 12/15/2021) 12/15/2021 547 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 12/15/2021 re: Opposition to restriction on expert testimony (Sternheim, Bobbi) (Entered: 12/15/2021) 12/15/2021 548 MEMORANDUM OPINION & ORDER as to Ghislaine Maxwell. The Defense on December 12, 2021, moved to permit three anticipated witnesses to testify under a pseudonym or their first names only. The Government filed a letter opposing this request on December 14, 2021. The Defense's primary contention is that some form of anonymity for its witnesses is justified by the same reasons that the Court permitted three alleged victims and two related government witnesses to testify under pseudonyms. The Court disagrees with this basic premise and denies the Defense's motion....[*** See this Memorandum Opinion & Order ***]... Last, the Court emphasizes that while it currently denies the Defense's motion, the Defense may of course raise, and the Court will consider, objections that particular lines of questioning into witnesses' backgrounds or lives are irrelevant, cumulative, intended to harass, or otherwise inappropriate. See, e.g., Smith v. Illinois, 390 U.S. 129, 133 (1968) (emphasizing that even when anonymity is not warranted, the court has a duty to protect a witness "from questions which go beyond the bounds of proper cross-examination merely to harass, annoy or humiliate him"). SO ORDERED. (Signed by Judge Alison J. Nathan on 12/15/2021)(bw) (Entered: 12/16/2021) 12/15/2021 694 ORDER as to Ghislaine Maxwell. The Court is in receipt of the Government's motion to preclude certain testimony of defense witnesses, dated December 15, 2021. The Defense is ORDERED to submit a response as follows: - A response to the motion with respect to Dr. Loftus by today, December 15, 2021, at 7:45 p.m. - A response to the motion with respect to Alexander Hamilton by tomorrow, December 16, 2021, at 7:00 a.m. - A response to the motion with respect to the other anticipated witnesses by tomorrow, December 16, 2021, at 5:00 p.m. SO ORDERED. (Signed by Judge Alison J. Nathan on 12/15/2021)(bw) (Entered: 06/29/2022) 12/16/2021 551 ORDER as to Ghislaine Maxwell: The Court is in receipt of the parties' joint letter regarding the admission of prior inconsistent statements. The parties' letter notes "that DOJ-OGR-00020459