Document Case 1:20-cr-00330

8/2/2021 Case 1:20-cr-00330 Document 241 Filed 08/02/21 Page 6 of 10 underage victim between 2001 and 2004. Her lawyers have asked for a delay until early next year. Prosecutors say they “strenuously” oppose the request. MOST READ Belarusian athlete claims she was forced to airport after complaining about Olympic coaches Kathy Griffin reveals lung cancer diagnosis Governors Ball dumps DaBaby after homophobic comments Judge Alison Nathan said she will soon rule on whether to postpone the start of trial. The judge recently ordered that Maxwell face a second trial on charges of lying under oath at a later date to be determined. Archived on 8/2/21 Ctr 20CR330 FEEDBACK This document is protected by copyright. Further reproduction is prohibited without https://www.nydailynews.com/new-york/ny-ghislain-maxwell-arraignment-20210423-b3aza5eh7bddna7r247px2yb7e-story.html 6/10 DOJ-OGR-00004970 --- PAGE BREAK --- 8/2/2021 Case 1:20-cr-00330 Document 571 Filed 08/02/21 Page 7 of 10 Isabel Maxwell, Ghislaine Maxwell's sister, leaves Manhattan Federal Court Friday, April 23, in Manhattan, New York. (Barry Williams/for New York Daily News) A legal battle is also brewing over a 2016 meeting — first revealed by the Daily News — between Manhattan federal prosecutors and attorneys for Epstein accusers. Sources told the Daily News that the victims' lawyers urged the office to open an investigation of Epstein and Maxwell. But the request went nowhere. Isabel Maxwell, Ghislaine Maxwell's sister, right, leaves Manhattan Federal Court Friday, April 23, in New York. (Barry Williams/for New York Daily News) Maxwell now cites that meeting as evidence that prosecutors and victims' lawyers were improperly in cahoots. Manhattan federal prosecutors say they opened an investigation of Epstein and Maxwell in response to investigative reporting by the Miami Herald in late 2018. Sources familiar with the meetings said victims' lawyers were frustrated by prosecutors' failure to take action following the outreach — rebutting Maxwell's claims of collusion. https://www.nydailynews.com/new-york/ny-ghislaine-maxwell-arraignment-20210423-b3aza5eh7bddna7r247px2yb7e-story.html 7/10 DOJ-OGR-00004971 --- PAGE BREAK --- 1/26/22, 3:30 PM Case 1:20-cr-00330 Ghislaine Maxwell Jurors say evidence convinced panel predator Daily Mail Online Maxwell (pictured with Epstein) faced six counts relating to sex trafficking which centered on the stories of four victims https://www.dailymail.co.uk/news/article-10370193/Ghislaine-Maxwell-juror-says-evidence-convinced-panel-predator.html 10/16 DOJ-OGR-00009184 --- PAGE BREAK --- 1/26/22, 3:30 PM Case 1:20-cr-00330 Ghislaine Maxwell Doesn't Say Evidence Convinced Her: Daily Mail Maxwell (pictured with Epstein) faced six counts relating to sex trafficking which centered on the stories of four victims https://www.dailymail.co.uk/news/article-10370193/Ghislaine-Maxwell-juror-says-evidence-convinced-panel-predator.html 10/16 DOJ-OGR-00009863 --- PAGE BREAK --- Haddon, Morgan and Foreman, P.C. Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com July 21, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (AJN), Local Criminal Rule 23.1 Dear Judge Nathan, On behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government, its agents, witnesses and their lawyers have made, and continue to make, statements prejudicial to a fair trial. The Sixth Amendment to the United States Constitution guarantees an accused the right to an impartial jury. This fundamental guarantee is part of a criminal defendant's basic right to a fair trial, which requires that a defendant must be judged by a jury of her peers based on evidence presented at trial, not in the media. The Court, to safeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly, Ms. Maxwell requests that the Court exercise its express power under Local Criminal Rule 23.1(h) and enter an Order requiring compliance with that rule to prevent further unwarranted and prejudicial pretrial publicity by the Government, its agents, and lawyers for alleged witnesses. Legal Standard More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the Supreme Court directed trial judges to take "such steps by rule and regulation that will protect their processes from prejudicial outside interferences. Neither prosecutors, counsel for defense, the accused, witnesses, court staff nor enforcement officers coming under the jurisdiction of the court should be permitted to frustrate its function." Sheppard v. Maxwell, 384 U.S. 333, 363 (1966) (emphasis added). App.031 DOJ-OGR-00019490