545 [DOJ-OGR-00008374—DOJ-OGR-00008382]

Case 1:20-cr-00330-PAE Document545 Filed 12/15/21 Page1of9 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 14, 2021 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 in opposition to the defendant’s request to call Jack Scarola, Brad Edwards, and Robert Glassman—all counsel for victims—to testify in the defendant’s case-in-chief. Rather than asking these attorneys about their conversations with their clients, which are privileged, the defendant seeks to elicit testimony about those attorneys’ conversations with the Government. This end-run around privilege, however, would only generate irrelevant evidence. The victims themselves have testified and been cross-examined about what they do and do not know or believe. There is no relevance to their lawyers’ conversations with the Government when the defendant has failed to establish the victim’s knowledge of those statements, nor would testimony about those conversations serve as proper impeachment, unless those conversations were in some way communicated to their clients. And that fact has not been DOJ-OGR- 00008374