320 [DOJ-OGR-00004994—DOJ-OGR-00004997]

Case 1:20-cr-00330-PAE Document 320 _ Filed 08/18/21 Page1of4 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 August 18, 2021 VIA 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 footnote 1 of the Court’s Opinion and Order denying the defendant Ghislaine Maxwell’s supplemental pretrial motions. (Dkt. No. 317). In that footnote, the Court noted that the defendant’s motion for a bill of particulars included a request that the Government identify her unnamed co-conspirators, as did her position in the parties’ joint letter regarding the disclosure schedule. The Court wrote that, because the Government had not objected, it “presumes the Government intends to disclose this information to Maxwell at the same time that . . . it discloses Jencks Act material.” (/d. at 12 n.1). To be clear, the Government objects to any requirement that it provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise, and does not intend to do so absent further order of the Court. ! ' The Government has opposed the defendant’s requests for such a list as part of its opposition to the defense motions for a bill of particulars. In the parties’ joint letter regarding the disclosure schedule, the defendant sought early disclosure of both the identities of unindicted co-conspirators and their statements. (Dkt. No. 291 at 7-8, 10-13). The Government took the position that the defense could “receive notice of any co-conspirator statements through Jencks Act materials and marked exhibits.” (/d. at 5). The Government also noted that “[t]he cases cited by the defense all DOJ-OGR-00004994