SDNY prosecutors' email on revised motions in limine, October 2021

Subject: RE: Revised MILs and letters Date: Mon, 18 Oct 2021 20:36:02 +0000¶

OK will do.¶

From: (USANYS) Sent: Monday, October 18, 20214:35 PM To: (USANYS) A Subject: RE: Revised MILs and letters >¶

Go ahead — I’m not in them. I didn’t have comments. And agree with the below.¶

From: (USANYS) < Sent: Monday, October 18, 2021 4:34 PM To: (USANYS) Subject: RE: Revised MILs and letters¶

Here are a few comments on the motion. I looked at the two letters also, and have one suggestion on each (I’m happy to propose language in redline, but you may be in the dots)¶

• 1. On the “key” letter would it be possible to include a sentence on pointing to Judge Nathan to whatever the article(s) in which she has made comments about Epstein that are far more limited than what she will say in court?
• 2. On the sealing letter I think we should add a sentence explaining why we think the claim of Maxwell abuse will cause prejudicial publicity. Namely, to air that issue in a public filing when there may well be no good faith basis for it would potentially taint the jury pool.

From:
	Sent: Monday, October 18, 2021 3:46 PM
To:	(USANYS)	>;	(USANYS)
Cc:	) C a	s;	(USANYS) <
Subject: Revised MILs and letters

Hi and¶

Attached for your review are:¶

• 1. Revised MILs
• 2. A redline
• 3. A draft cover letter
• 4. A draft index letter with victim information

Thanks!¶

Assistant United States Attorney Southern District of New York¶

New York, New York 10007¶