539 [DOJ-OGR-00008357—DOJ-OGR-00008359]

Case 1:20-cr-00330-PAE Document539_ Filed 12/12/21 Page1lof3 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 December 12, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter seeking an order directing the defense to provide the Government with the witnesses it anticipates calling next week by 10:00 a.m. tomorrow, December 13, 2021.! The Government previewed for several days prior to the close of the Government’s case that it would rest sometime last week. Following the close of the Government’s case, the Government requested that the defense provide the Government with Rule 26.2 material, along with “a list of witnesses, and an order of the first witnesses.” Tr. 2276. The Court ordered the defense to do so, stating, “Yes. You’ll do that.” Jd. ' The defense also made an untimely production of Rule 16 materials on Friday evening, following the close of the Government’s case. The Government will file a motion to preclude later this evening. 1 DOJ-OGR-00008357