Case 1:20-cr-00330-PAE Document 489 _ Filed 11/22/21 Pagelof2
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=] COHEN & GRESSER LLP New York, NY 10022
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Christian R. Everdell
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[email protected]
November 20, 2021
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response
to the government’s letter motion, dated November 11, 2021, requesting that the Court find that
the birth certificates for the alleged Minor Victims (GX-11 through GX-16) are self-authenticating
under the Federal Rules of Evidence.
We have reviewed the government’s submission and, in the interests of facilitating an
efficient trial, we are prepared to stipulate to the authenticity of the birth certificates for alleged
Minor Victim-1 (GX-12), Minor Victim-2 (GX-13), Minor Victim-4 (GX-11), Minor Victim-5
(GX-14), and Minor Victim-6 (GX-15). We will coordinate with the government to produce an
appropriately worded stipulation as to the authenticity of these exhibits.
However, the government itself concedes that it has not yet proffered a sufficient
foundation to authenticate the birth certificate of Witness-3 (GX-16). See 11/11/2021 Gov’t Ltr. at
1n.2. According to GX-16, Witness-3 was born is In order for such a
record to be self-authenticating as a foreign public document, the government must meet the
requirements of Rule 902(3) of the Federal Rules of Evidence, which it has not yet done. The
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