Document 541

Case 1:20-cr-00330-PAE Document 541 Filed 12/13/21 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 13, 2021 BY ECF 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 question whether the pending privilege issue could be resolved by a stipulation regarding the testimony of Robert Glassman. After considering the issue and conferring with defense counsel, the Government remains of the view that the statement in the email is not admissible and requires additional context for it to be understandable by the jury. (See Gov't Letter at 7-8, Dkt. No. 528; 12/6/21 Letter from Robert Glassman at 3-4). Accordingly, the Government would not enter into such a stipulation. 1 DOJ-OGR-00008361 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 541 Filed 12/13/21 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 ECF) 2 DOJ-OGR-00008362