411 [DOJ-OGR-00006162—DOJ-OGR-00006164]

_ Case 1:20-cr-00330-PAE Document 411 Filed 11/04/21 Page1of3 aN 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 November 4, 2021 BY 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 moves for reconsideration of the portions of the Court’s order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021. This schedule provides the Government seven days—or six, if timed from the Court’s order—to respond to the defense’s expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1 Moreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant’s motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co- conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3’s testimony ' The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness. DOJ-OGR-00006162