455 [DOJ-OGR-00006950—DOJ-OGR-00006952]

Case 1:20-cr-00330-PAE Document 455 Filed 11/12/21 Page1of3 > 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 12, 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 submits this letter seeking clarification on two items from the November 1, 2021 pretrial conference. First, when describing the defendant’s ability to cross-examine witnesses who will be testifying under pseudonyms, the Court explained that: All lines of inquiry the defense outlined in its response are available without disclosing specific names of employers or other specifically identifying information. For example, the defense can probe the genre, nature, and trajectories of witnesses' careers without eliciting the specific employer name, but the defense's cross-examination should not include specifically identifying information, and counsel must act responsibly doing so. (11/01/21 Tr. at 11:20-12:2). The Government seeks clarification before trial about the line between permissible and impermissible cross-cxamination [iin DOJ-OGR-00006950