Case 1:20-cr-00330-PAE Document 331 Filed 08/30/21 Page1lof5
iy Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
HADDON
MORGAN 150 East 10th Avenue
FOREMAN Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
[email protected]
August 30, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New York, NY 10007
Re: | Response to Government Letter dated August 18, 2021, Dkt. 320, United States v.
Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write in response to the government’s letter dated August 18, 2021, Dkt. 320, which
raises two issues.!
Identities of Co-Conspirators
The government first attempts to walk back its multiple concessions regarding disclosure
of the identities of the unnamed co-conspirators alleged in the S2 indictment.
As this Court noted, Ms. Maxwell has on at least two occasions requested such
disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered
disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the
government finally object. The government’s objection comes too late.
' As directed by the Court, on August 24 the parties conferred about the government’s
letter, but they were unable to reach an agreement on the government’s requests for
reconsideration.
DOJ-OGR-00005019