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Case 1:20-cr-00330-AJN Document 41 Filed 08/13/20 Page 1of5 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 August 13, 2020 VIA 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 in opposition to the defendant’s letter of August 10, 2020 (the “Defense Letter” or “Def. Ltr.”), requesting that the Court order the Government to disclose the names of certain Government witnesses 11 months prior to trial, and requesting that the Court intervene in the protocols and individualized inmate determinations of the Bureau of Prisons. Both applications should be denied. A. The Defendant’s Demand That the Government Name Certain Trial Witnesses For the third time in as many weeks, the defendant and her counsel have applied to the Court for relief that is premature, meritless, or both. See Order dated July 23, 2020 (Dkt. 28) (denying the defendant’s request that the Court enter an order prohibiting the Government and attorneys for non-parties from making extrajudicial statements “concerning this case”); Order dated July 30, 2020 (Dkt. 37) (denying the defendant’s application for a protective order that would allow the defense to publicly name and identify victims). In the defendant’s most recent application, she asks the Court to order that the Government disclose a partial witness list, in the form of identifying certain victims referenced in the Superseding Indictment (the “Indictment’’), fully 11 months prior to trial. This request is at best premature given that the production of discovery, on the schedule agreed to by the defendant, has just begun. Moreover, the parties have had no discussions about—let alone asked the Court to set—a schedule for pretrial disclosures, including for witness lists and 3500 material. In the first instance, the defendant complains about the status of discovery production, arguing that “almost six weeks since” the arrest of the defendant, the Government is “just now beginning to produce Rule 16 discovery, despite confirming to the Court that discovery would begin as soon as the Court entered a protective order.” Def. Ltr. at 2. The suggestion that the Government somehow delayed that initial production is nonsense. As the Court is aware, the DOJ-OGR-00001719