Case 1:20-cr-00330-PAE Document521 Filed 12/03/21 Page1of5
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
December 3, 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,
During her cross-examination, Jane denied knowing that cooperating with the
government in the prosecution of Ms. Maxwell and testifying against her would help her civil
case against Ms. Maxwell and her claim for compensation from the Epstein Victims’
Compensation Program (EVCP). Because Jane denied having this knowledge, Ms. Maxwell has
a constitutional right to call Jane’s attorney (Robert Glassman) as a witness and to ask him
whether he told Jane that cooperating and testifying against her would “help her case.” U.S.
Const. amends. V, VI. This issue is relevant to Jane’s motive to cooperate and testify,' and it’s
' Davis v. Alaska, 415 U.S. 308, 316 (1974) (“A more particular attack on the witness’
credibility is effected by means of cross-examination directed toward revealing possible biases,
prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities
in the case at hand. The partiality of a witness is subject to exploration at trial, and is always
relevant as discrediting the witness and affecting the weight of his testimony.” (quotation
omitted)).
DOJ-OGR-00008206