Case 1:20-cr-00330-PAE Document 494 _ Filed 11/22/21 Page1of12
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Christian R. Everdell
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November 11, 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 (i) the government’s November 5, 2021 letter in further opposition to Ms. Maxwell’s Motion in
Limine to Exclude Evidence Related to Accuser-3 (Dkt. 387), and (ii) the government’s November
7, 2021 letter in response to the Court’s order, dated November 6, 2021, directing the government
“to state its position as to whether this anticipated witness could be deemed a victim of any of the
crimes charged in the indictment for any legal purpose.” (Dkt. 417). For the reasons set forth
below and in our prior motion, the evidence related to Accuser-3 is not direct evidence of any of
the conspiracies charged in the S2 Indictment and is improper propensity evidence that should be
excluded under Rule 404(b) and Rule 403 of the Federal Rules of Evidence.
1. Accuser-3’s Evidence Is Not Direct Evidence of Any Conspiracy Charged in the S2
Indictment
The Court asked the government to do two things at the November 1, 2021 pretrial
conference concerning the admissibility of Accuser-3’s evidence: (1) provide additional briefing
on why Accuser-3’s evidence could potentially be admitted as direct evidence of the sex
trafficking conspiracy charged in Count Five, and (i1) outline in further detail Accuser-3’s
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