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U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building USDC SDNY
One Saint Andrew's Plaza DOCUMENT
New York, New York 10007 Ee i
ELECTRONICALLY FILED
April 19, 2021 DOC #;
ee pate FILED: 4/20/21
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 writes with respect to the Court’s Order dated April 19, 2021, which
directed the Government to notify the Court by tomorrow whether it intends to “use any of the
documents subject to the pending motions to suppress in the trial of the non-perjury counts in this
case.” (Dkt. No. 216). The Government respectfully requests that the Court grant the Government
until Thursday, April 22, 2021, to submit its response.
The Government is carefully considering the Court’s Order, and has begun reviewing its
file, considering legal issues, and having internal conversations with supervisors in order to
thoughtfully and accurately respond to the Court. In particular, although the materials at issue are
not likely to be central to the Government’s case in chief in the trial of the non-perjury counts, the
Government nonetheless recognizes the importance of anticipating how these materials may be
relevant to (and used at) the trial. For example, and among other considerations, the materials
include transcripts of depositions of witnesses who may testify at trial, and the Government is
mindful of potential uses of such material that might arise during the cross-examination of both
Government and defense witnesses whose prior statements are encompassed within the materials
at issue.
DOJ-OGR-00003863