554 [DOJ-OGR-00008428—DOJ-OGR-00008430]

Case 1:20-cr-00330-PAE Document554 _ Filed 12/18/21 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 18, 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 writes regarding the two issues remaining following today’s charge conference. First, the Government opposes the addition of Sand instruction 7-12 regarding the impeachment of witnesses by felony convictions. That limiting instruction is meant to “tell the jury why the felony conviction was put before them.” Sand Instr. 7-12 cmt. It is useful in cases in which the prior felony convictions are sufficiently significant that they are an important part of the defense, and an explanation would aid the jury in evaluating the evidence. In such a case, it aids the jury to know that the prior conviction was offered solely for the purpose of evaluating the witness’ credibility. Here, the only witnesses whose prior convictions were elicited are Carolyn DOJ-OGR- 00008428