Case 1:20-cr-00330-PAE Document566- Filed 12/28/21 Pagelof7
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Christian R. Everdell
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December 27, 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, NY 10007
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN)
Dear Judge Nathan:
We respectfully submit this letter to request that the Court give the jury additional
instructions to correct apparent errors in the jury’s understanding of Counts Two and Four, and the
law applicable to those counts, that were highlighted by the jury’s note this afternoon (Court
Exhibit #15).
Court Exhibit #15 reads, in relevant part, as follows:
Under Count Four (4), [i]f the defendant aided in the transportation of Jane’s return
flight, but not the flight to New Mexico where/if the intent was for Jane to engage
in sexual activity, can she be found guilty under the second element?
Count Four alleges that Ms. Maxwell “arranged for [Jane] to be transported from Florida
to New York, New York on multiple occasions with the intention that [Jane] would engage in one
or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55.” S2
Ind. § 21 (emphasis added).
In response to the note, the Court referred the jury to Instruction No. 21 of the jury charge.
The defense believes that the Court’s response was erroneous for two reasons.
2068538.1
DOJ-OGR-00008790