456 [DOJ-OGR-00006953—DOJ-OGR-00006962]

Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page1of10 : 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 in support of the admission of certain statements by the defendant’s co-conspirators at trial pursuant to Federal Rule of Evidence 801(d)(2)(E). Consistent with the Court’s directives at the November 1, 2021 conference in this case, the Government has provided the defense with categories of co-conspirator statements it intends to offer at trial, as well as examples of particular statements within each category. After conferral, the defense indicated that, subject to certain clarifications, it would not object to the majority of the proffered statements. The defense further indicated that it objected to a particular subset of the Government’s proffered statements. For the reasons set forth below, the Court should admit these statements at trial. A. The Proffered Statements The Government identified four categories of statements by co-conspirators of the defendant that the Government may seek to admit at trial: (1) statements made by Epstein to friends and family of Minor Victims; (2) statements made by Epstein to his employees; (3) statements made by a co-conspirator to the Minor Victims or their families; and (4) statements made by DOJ-OGR-00006953