199 [DOJ-OGR-00002913—DOJ-OGR-00002920]

Case 1:20-cr-00330-PAE Document199_ Filed 04/09/21 Page1of8 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 April 9, 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, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the defense letter dated March 31, 2021 (Dkt. No. 192), and pursuant to the Court’s Order dated April 2, 2021 (Dkt. No. 193). As set forth below, the timing of superseding indictment S2 20 Cr. 330 (AJN) (the “S2 Indictment”) was dictated by developments in the Government’s ongoing investigation, not the nefarious motivations suggested by the defense. Although trial may be modestly longer as a result, the S2 Indictment by no means opens the floodgate of witnesses the defense imagines; to the contrary, the Government expects to present a streamlined case focusing primarily on the four minor victims referenced in the S2 Indictment. Moreover, the Government has already taken, and will continue to take, steps to ensure that the defense will be fully prepared for trial as scheduled in July. Accordingly, the Government would oppose any request for an adjournment of trial. Finally, the addition of new charges, supported by even more evidence, in no way warrants reconsideration of this Court’s three prior orders denying the defendant bail. First, the Government obtained the S2 Indictment based on new evidence that was not available to it at the time the defendant was indicted in 2020 or at the time Jeffrey Epstein was indicted in 2019. Specifically, although Minor Victim-4 had previously been interviewed once in DOJ-OGR-00002913