Case 1:20-cr-00330-PAE Document 234
Cy
HADDON
MORGAN
FOREMAN
April 22, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Filed 04/22/21 Pagelof5
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.hmilaw.com
[email protected]
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Response to Dkt. No. 227, Government’s April 21, 2021 Letter re Ms. Maxwell’s
Motions to Suppress
Dear Judge Nathan:
We write in response to the government’s letter about Ms. Maxwell’s pending motions
to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court’s order stating
an intent to defer resolution of those motions and that request until after the trial on the non-
perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial
process and the desire to efficiently resolve the pending disputes, we do not agree that the
government’s letter provides an adequate basis to defer resolution of Ms. Maxwell’s motions.
We understand the Court’s desire to maintain the status quo relating to the defense motions,
but the government’s response gives Ms. Maxwell no confidence that the government shares
this understanding. Indeed, the government’s vague assurances are insufficient to safeguard
Ms. Maxwell’s constitutional rights, to guarantee the government will not benefit from its
unconstitutional conduct, and to ensure that Ms. Maxwell’s is not deprived of due process
through the introduction and use of evidence that itself was obtained in violation of due
process.
DOJ-OGR- 00003938