Court Filing - Letter to Judge: 717
Summary
The defense team for Ghislaine Maxwell requests that three witnesses be allowed to testify using pseudonyms or their first names only, citing substantial professional and personal privacy interests, and arguing that this is necessary to protect their constitutional rights to present a defense and effective assistance of counsel.
This document is from the epstein-docs Archive.
View Source CollectionPersons Referenced (4)
Related Documents (6)
Court Filing - Letter to Judge: 723
The defense attorney for Ghislaine Maxwell argues that the testimony of Eva Dubin, Michelle Healy, and Kelly Bovino is relevant, material, and exculpatory, contradicting Jane's testimony about group sexualized massages involving Maxwell and Jeffrey Epstein. The defense asserts that excluding this testimony would violate Maxwell's right to present a defense and confront her accusers.
Court Filing - Letter Motion: 120366003830
The letter is a reply in support of Ghislaine Maxwell's request to modify a protective order to allow her to disclose certain information to civil litigation under seal. The government opposes the request, claiming it will jeopardize an ongoing criminal investigation, but Maxwell's attorney argues that the government's arguments lack merit.
Letter to the Court: 120366003830-Adt. Doc.0812412530-Filing808908P20ePage01of03
The letter, submitted by Ghislaine Maxwell's counsel, proposes redactions to her Request to Modify Protective Order and Reply, and objects to the government's proposed redactions, arguing they go beyond what is required by the Protective Order.
Letter to the Judge: 370
The letter, written by Jeffrey S. Pagliuca, informs Judge Alison J. Nathan that Ghislaine Maxwell's Omnibus Response has been filed temporarily under seal. The response will be refiled publicly with proposed redactions by October 29, 2021, along with a justification for those redactions.
Court Filing - Letter to Judge: 377
The letter is from Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding Ghislaine Maxwell's motion under Federal Rule of Evidence 412. The motion is being filed under seal due to the Rule's requirements, and the defense will serve redacted copies to the alleged victims' counsel. The letter outlines the steps being taken to comply with the Rule.
Court Filing - Letter to Judge: 521
The letter, filed by Ghislaine Maxwell's attorneys, argues that Maxwell has a constitutional right to call Jane's attorney, Robert Glassman, as a witness to testify about his advice to Jane regarding cooperating with the government and testifying against Maxwell. The attorneys contend that the attorney-client privilege does not apply or has been waived, and that Glassman's testimony is relevant to Jane's credibility and Maxwell's defense.
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.