Ghislaine Maxwell proposes the disclosure of victims and unindicted co-conspirators by Sep 27th, many weeks before the trial.

The Government will provide the defense with the identities of the victims referenced in

the S2 Indictment by September 13, 2021, or 11 weeks in advance of trial. The Government

understands that the defense requests that the Government disclose the identities of the victims

immediately. The Government notes that the parties previously agreed, and the Court ordered,

that the Government would provide the defense with the identities of the victims 8 weeks before

trial, on May 17, 2021, assuming trial were to begin as scheduled on July 12, 2021. (Dkt. No. 229,

250). The Government’s proposal would provide the defense with the victims’ identities

substantially in advance of trial. See, e.g., United States v. Kee, No. 98 Cr. 778 (DLC), 2000 WL

760096, at 1-2 n.2 (S.D.N.Y. June 12, 2000) (requiring Government to disclose identities of

victims approximately 45 days in advance of trial).

https://www.courtlistener.com/docket/17318376/291/united-states-v-maxwell/