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Case 1:20-cr-00330-PAE Document541 Filed 12/13/21 Pagelof2
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 13, 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, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter regarding the question whether the
pending privilege issue could be resolved by a stipulation regarding the testimony of Robert
Glassman. After considering the issue and conferring with defense counsel, the Government
remains of the view that the statement in the email is not admissible and requires additional context
for it to be understandable by the jury. (See Gov’t Letter at 7-8, Dkt. No. 528; 12/6/21 Letter from
Robert Glassman at 3-4). Accordingly, the Government would not enter into such a stipulation.
DOJ-OGR- 00008361