Case 1:20-cr-00330-PAE
Cy
HADDON
MORGAN
FOREMAN
October 18, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Document 358
Filed 10/18/21 Page1of4
Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
[email protected]
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Today, counsel for Ghislaine Maxwell filed 13 motions in /imine and accompanying
exhibits seeking the following relief:
to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for
Failing to Comply with This Court's September 3, 2021 Order;
to Exclude Any Evidence Offered by the Government Pursuant to Fed. R. Evid. 404(b)
for Failure to Comply with the Rule's Notice Requirement;
to Exclude Under Federal Rule of Evidence 702 and Daubert v. Merrell Dow
Pharmaceuticals, Inc., 509 U.S. 579 (1993) and Request for Daubert Hearing;
to Exclude Evidence Related to Accuser-3;
to Exclude Evidence of Alleged Flight;
to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact
Allegations Related to the Perjury Counts from the Second Superseding Indictment;
DOJ-OGR-00005260