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Document 271

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Case 1:20-cr-00330-PAE Document 271 Filed 05/06/21 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 May 6, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to supplement its letter of May 4, 2021 (Dkt. No. 269) regarding Requests 9 through 11 of the defendant's requested subpoena to Boies Schiller Flexner LLP. As noted in the Government's letter, the Government has produced to the defense copies of the photographs sought in Request 11. (Dkt. No. 269 at 8). The Government has now determined that, for a subset of the photographs requested by the defendant, the Government previously provided the defense with scanned images of this subset of photographs from the FBI Florida file. The original photographs are currently in the FBI's possession. Accordingly, because some of the original photographs are currently in the Prosecution Team's possession, the Government will make them available to the defendant for inspection upon request. Request 11 is therefore moot as to those photographs. DOJ-OGR-00004105 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 271 Filed 05/06/21 Page 2 of 2 Page 2 As to the remaining photographs that are outside the Government's possession, because the defendant has copies of those photographs, the originals are not a proper subject of a Rule 17 subpoena. Accordingly, for the reasons set forth in the Government's letter, Request 11 should otherwise be denied. Respectfully submitted, AUDREY STRAUSS United States Attorney By: s/ Maurene Comey / Alison Moe Lara Pomerantz / Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00004106

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Page 1 of 2 - DOJ-OGR-00004105
Case 1:20-cr-00330-PAE Document 271 Filed 05/06/21 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 May 6, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to supplement its letter of May 4, 2021 (Dkt. No. 269) regarding Requests 9 through 11 of the defendant's requested subpoena to Boies Schiller Flexner LLP. As noted in the Government's letter, the Government has produced to the defense copies of the photographs sought in Request 11. (Dkt. No. 269 at 8). The Government has now determined that, for a subset of the photographs requested by the defendant, the Government previously provided the defense with scanned images of this subset of photographs from the FBI Florida file. The original photographs are currently in the FBI's possession. Accordingly, because some of the original photographs are currently in the Prosecution Team's possession, the Government will make them available to the defendant for inspection upon request. Request 11 is therefore moot as to those photographs. DOJ-OGR-00004105
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Case 1:20-cr-00330-PAE Document 271 Filed 05/06/21 Page 2 of 2 Page 2 As to the remaining photographs that are outside the Government's possession, because the defendant has copies of those photographs, the originals are not a proper subject of a Rule 17 subpoena. Accordingly, for the reasons set forth in the Government's letter, Request 11 should otherwise be denied. Respectfully submitted, AUDREY STRAUSS United States Attorney By: s/ Maurene Comey / Alison Moe Lara Pomerantz / Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00004106