Case 1:20-cr-00330-PAE Document519_ Filed 11/30/21 Page1of3
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
My 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
[email protected]
HADDON
MORGAN
FOREMAN
November 30, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
I write following our conferral with the government about protecting the anonymity of
certain testifying witnesses in this case. The government suggested to us that we must avoid any
public mention of: (1) names of people, places, or specific addresses or locations; (2) particular
dates of career events or life events; (3) names of any employers, particular performances, or
characters played; (4) specific details of story arcs in any performances played; (5) references to
publicly available information or publicly available records that contain a pseudonymous
witness’s real name; and (6) court filings or other court documents.
Respectfully, the government’s proposal is overly broad and unworkable.
We are mindful of the Court’s orders on this topic, and we have no objection to many of
the government’s suggestions—e.g., the names of people or specific addresses or particular
employers. But the government’s proposal reaches much too far, and it would unfairly constrain
Ms. Maxwell’s ability to meaningfully and effectively confront her accusers. U.S. Const. amend.
VI.
DOJ-OGR- 00008202