Document 733

Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Page 1 of 2 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com November 28, 2021 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the government's letter, dated November 27, 2021, seeking to preclude certain topics of cross-examination.1 The defense does not intend to cross-examine Accuser-1 or Accuser-2 about [REDACTED] unless their testimony opens the door to such cross-examination. Similarly, the defense does not intend to cross-examine Accuser-1 about [REDACTED] unless the witness's testimony opens the door to such cross-examination. However, Accuser-1's brother, who is a testifying witness, told the government less than three weeks ago that [REDACTED]. 1 Pursuant to our established protocol, the defense is submitting this letter to the Court under temporary seal to allow the government to propose any appropriate redactions. DOJ-OGR-00011449 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Page 2 of 2 The Honorable Alison J. Nathan November 28, 2021 Page 2 should be permitted to cross-examine Accuser-1 about because it is relevant to her ability to recall the events in question accurately. As the government concedes, it is The defense Respectfully submitted, Jeffrey S. Pagliuca CC: Counsel of Record DOJ-OGR-00011450