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Correspondence · Oct. 14, 2021

Correspondence, 2021-10-14

Email chain among SDNY prosecutors exchanging and commenting on draft motions in limine ahead of Ghislaine Maxwell's trial.Machine-written summary

Subject: RE: Maxwell MILs

Date: Thu, 14 Oct 2021 16:03:05 +0000

Attachments: Government_MIL_v1_for_chiefs___TAM.docx

Here are my proposed edits and comments. A bunch of my comments are the same as yours, or propose ways to address things you flagged – but I do think at least some of your comments are outstanding. Rather than me trying to decide which ones need further response, would you like to take a look at this and then add any additional comments?

Sent: Thursday, October 14, 2021 9:09 AM

To: (USANYS) <

Subject: RE: Maxwell MILs

Ok, if helpful, my comment bubbles are in the attached.

Sent: Wednesday, October 13, 2021 11:36 PM

Subject: RE: Maxwell MILs

I just read through them in hard copy, and then am going to suggest some changes in track tomorrow (if we ever have time between what is now a packed calendar). I’m happy to add them on top of yours, or send to you when done, either way.

Sent: Wednesday, October 13, 2021 6:53 PM

To: (USANYS) <

Subject: RE: Maxwell MILs

I’ve taken a first pass through the MILs. I didn’t line edit, figuring you would do so, but put general comments in bubbles for certain sections/arguments. I can forward that to you, or wait until I see your comments and add any of mine that remain. Overall I think it could be tighter but they are on the right track.

Subject: RE: Maxwell MILs

Thanks, looking forward to reading.

Subject: Maxwell MILs

EFTA00065492

Hey

Attached are drafts of most of the Maxwell MILs. This draft has all but two of the motions and the front matter.

We’re planning to do a careful proofread, but thought we should just get these to you now rather than wait for that. All comments are more than welcome, of course.

Thanks,

Assistant United States Attorney

Southern District of New York

1 Saint Andrews Plaza

New York, New York 10007

EFTA00065493

Correspondence, 2021-10-14

Emails and letters

Email chain among SDNY prosecutors exchanging and commenting on draft motions in limine ahead of Ghislaine Maxwell's trial.

DOJ Epstein Files, Data Set 9 · Oct. 14, 2021

Subject: RE: Maxwell MILs Date: Thu, 14 Oct 2021 16:03:05 +0000 Attachments: Government MIL v1 for chiefs TAM.docx Here are my proposed edits and comments. A bunch of my comments are the same as yours, or propose ways to address things you flagged – but I do think at least some of your comments are outstanding. Rather than me trying to decide which ones need further response, would you like to take a look at this and then add any additional comments? Sent: Thursday, October 14, 2021 9:09 AM To: (USANYS) < Subject: RE: Maxwell MILs Ok, if helpful, my comment bubbles are in the attached. Sent: W…