Case 1:20-cr-00330-PAE
Cy
HADDON
MORGAN
FOREMAN
October 27, 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 377
Filed 10/27/21 Page1iofi
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:
Attached is Ms. Maxwell’s motion under Federal Rule of Evidence 412. Subsection
(2)(c) of the Rule requires this motion to be sealed unless this Court orders otherwise.
Accordingly, unless instructed by the Court, Ms. Maxwell will not file this motion on the public
docket.
The Rule also requires Ms. Maxwell to notify the alleged victims whose behavior is at
issue in the motion. Accordingly, unless otherwise directed, we will serve a redacted copy of this
motion tailored to each alleged victim addressed in the motion on their counsel of record and
provide proof of service to the Court when it is accomplished.
Respectfully Submitted,
y—
Jeffrey S. Pagliuca
CC: Counsel of Record (via ECF)
DOJ-OGR-00005389