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Case 1:20-cr-00330-PAE Document549 Filed 12/17/21 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 17, 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 files this letter in advance of the expected testimony of law enforcement
agents. From conferring, the Government understands that the defense intends to ask questions of
at least one law enforcement witness beyond those questions that elicit prior inconsistent
statements (to which the Government has generally offered to stipulate, insofar as they are
admitted).
In advance of the agents’ testimony, the Government writes regarding the boundaries of
the Court’s prior rulings on the scope of questions put to law enforcement witnesses. Specifically,
and pursuant to the Court’s rulings at the November 1, 2021 conference (attached as Exhibit A),
the Government will object to any questions about “the failure to utilize some particular technique”
DOJ-OGR-00008393