414 [DOJ-OGR-00006169—DOJ-OGR-00006171]

iigieaae se — CéaeSb: ALO OCKEBP AEN Domumresnit4id ribet OMe Pataye aft 3 U.S. Department of Justice United States Attorney Southern District of New York Uspe SDNY DOCUMENT ELECTRONICALLY FILED DOC #; DATE FILED: 11/4/21 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 The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 4, 2021 The Court hereby DENIES the Government's request as to Dr. Park Dietz and Dr. Elizabeth Loftus. Pursuant to this Court's Order, if the Government seeks to exclude these anticipated witnesses, briefing must be submitted by November 8, 2021. Dkt. No. 409. As to the remaining individuals disclosed in Defendant's notice, the Court GRANTS the Government's request. If the Government seeks to exclude those anticipated witnesses, briefing must be submitted by November 15, 2021, with a response by Defendant due November 19, 2021. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) AN igo Dear Judge Nathan: 11/4/21 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-00006169