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Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page1of3
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 21, 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 Court’s Order dated
April 19, 2021, which directed the Government to notify the Court 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). As an initial matter, the Government strongly opposes the
defendant’s suppression motions, and the Government respectfully submits that the Court should
deny the motions on the merits without an evidentiary hearing. However, in the interest of
efficiency, and with the goal of streamlining matters in advance of trial, the Government
respectfully submits that the Court need not resolve the pending suppression motions in advance
of the trial on the non-perjury counts.
Resolution of the suppression motions is not necessary at this juncture, because, after
considering the matter, the Government does not intend to use these materials in its case-in-chief
at the trial of the non-perjury counts in this case. However, the Government notes that the materials
DOJ-OGR-00003918