House Oversight — DOJ production
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Case 1:20-cr-00330-PAE Document 714 Filed 07/12/22 Pagelof7 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 November 21, 2021 BY E-MAIL 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, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter regarding the proposed limiting instructions in the Court’s order regarding Witness-3. (See Dkt. No. 477). The Government proposes one edit to the instruction in advance of Witness-3’s testimony. Specifically, the Government proposes inserting the word “solely” in the sentence beginning “However,” as follows: However, you may not convict the Defendant solely on the basis of the testimony regarding the sexual conduct between this witness and Mr. Epstein. This edit clarifies a potential tension within the instruction. As the Court has ruled, evidence relating to Witness-3 is relevant to the issues, but cannot on its own support a conviction. Absent this clarification, it may appear to the jurors that they “may not convict the Defendant on the basis of [Witness-3]’s testimony,” i.e., the testimony is not offered as relevant evidence the 1 DOJ-OGR-00011304 Case 1:20-cr-00330-PAE Document 714 Filed 07/12/22 Page2of7 jury may consider, but rather as background information or for some other purpose. That sentence would then conflict with the sentence in the instruction that the jury may consider the evidence to the extent it “is relevant to the issues before [the jury].” The Government proposes this edit to avoid any potential confusion by the jury. The Government respectfully objects to the second proposed limiting instruction! and submits that such an instruction should not be given. As an initial matter, the Government believes any such instructi […]