Case 1:20-cr-00330-PAE Document 267 Filed 05/03/21 Pagelof7
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
[email protected]
HADDON
MORGAN
FOREMAN
May 3, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Joint Letter re. defense witness disclosures, Dkt. No. 250
Dear Judge Nathan:
Pursuant to your order of April 26, 2021, Dkt. No. 250, the respective positions of the
parties regarding the timing of any defense Fed. R. Crim. P. 26.2 disclosures are set forth below.
Ms. Maxwell’s Position
Ms. Maxwell does not agree with the government’s proposal that she submit witness
statements pursuant to Federal Rule of Criminal Procedure 26.2 at least four weeks in advance of
trial. No statute or rule requires disclosure of either non-expert witness lists or Rule 26.2
material in advance of trial. Furthermore, the defense has not been given any specific dates
related to any alleged illegal activity nor has the government disclosed the actual identity of any
alleged victim or witness. Accordingly, it is impossible to identify any affirmative witness who
might, for example, place Ms. Maxwell in a different location at a specific date and time. Until
the government completes the presentation of its evidence at trial, the defendant will not be able
to identify definitively witnesses that may be relevant or necessary. A court order for pretrial
DOJ-OGR-00004084