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Document 538

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Case 1:20-cr-00330-PAE Document 538 Filed 12/11/21 Page 1 of 2 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 December 9, 2021 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 Court's order for the parties to confer and propose a limiting instruction regarding Government Exhibit 52. The parties have conferred and jointly propose the following instruction: This exhibit is being offered for a limited purpose. It is not being offered for the truth of the matters asserted therein, and you may not consider it for that purpose. Rather, you may consider it only to the extent you believe it is relevant to show a link, if any, between Ms. Maxwell and the names and phone numbers listed and how, if at all, the information was organized. 1 DOJ-OGR-00008355 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 538 Filed 12/11/21 Page 2 of 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) 2 DOJ-OGR-00008356

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Page 1 - DOJ-OGR-00008355
Case 1:20-cr-00330-PAE Document 538 Filed 12/11/21 Page 1 of 2 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 December 9, 2021 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 Court's order for the parties to confer and propose a limiting instruction regarding Government Exhibit 52. The parties have conferred and jointly propose the following instruction: This exhibit is being offered for a limited purpose. It is not being offered for the truth of the matters asserted therein, and you may not consider it for that purpose. Rather, you may consider it only to the extent you believe it is relevant to show a link, if any, between Ms. Maxwell and the names and phone numbers listed and how, if at all, the information was organized. 1 DOJ-OGR-00008355
Page 2 - DOJ-OGR-00008356
Case 1:20-cr-00330-PAE Document 538 Filed 12/11/21 Page 2 of 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) 2 DOJ-OGR-00008356