322 [DOJ-OGR-00005001—DOJ-OGR-00005004]

Cétash: 2Q20r OCR REP AON Demument220 ArbelOes15y221 Pategt afef 4 USDC SDNY es Ne, U.S. Department of Justice ELECTRONICALLY FILED DOC #: ; P DATE FILED: 8/19/21 United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Fiza | The parties are hereby ORDERED to meet and confer in an effort to reach an agreement on the August 18, 2021 disclosure issues raised in this VIA ECF ; letter. If the parties reach an Ce enera ison C - Nathan agreement, they shall inform the Court by August 26, 2021. If the Southern District of New York I. ie ti . ‘ h t th United States Courthouse ¢ Danes G0 NOL TAG agreements te 40 Foley Square coompenen gr ema) Defendant may file a response to New York. New York 10007 iia ay. the arguments made here by the , Government on or before August Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) |39, 2921. Any response letter shall confirm that the meet and confer Dear Judge Nathan: occurred. SOORDERED. 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-00005001