DOJ-OGR-00020560.jpg

Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page/4 of 92 (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 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 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 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 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 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) 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 12/16/2021 \a) in Lt DOJ-OGR-00020560