Case 1:20-cr-00330-AJN Document 511 Filed 11/27/21 Page 1 of 3
LAW OFFICES OF BOBBI C. STERNHEIA\
212-243-1100 * Main 225 Broadway, Suite 715
917-912-9698 ® Cell New York, NY 10007
888-587-4737 ° Fax
[email protected]
November 27, 2021
Honorable Alison J. Nathan
United States District Judge
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 to request a
clarification of the Court’s instructions regarding the use of paper documents versus electronic
documents at trial. In particular, the defense is still unclear whether we will be permitted to display
documents used for impeachment or refreshing a witness’s recollection in electronic format solely on the
video screens used by the witness, the Court, and the Court’s deputy, or whether we will be required to
provide paper copies of these materials, even if the materials do not reference a witness who is testifying
under a pseudonym. !
The defense is sensitive to the Court and the government’s concerns that people sitting in the
gallery of the courtroom do not see any documents that identify the witnesses who are testifying under
pseudonyms. We also understand that the Court wants to ensure that the witnesses will have access to
the complete documents that may be used for impeachment and refreshing recollection, rather than a
' Counsel for the defense understood the discussion on November 23, 2021, to apply only to documents which
contained identifying information for witnesses who are testifying under pseudonyms or first names. The
government, however, has suggested that paper documents need to be used for all impeachment and refreshing,
whether or not the documents contain such identifying information.
DOJ-OGR-00008166