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Case 1:20-cr-00330-PAE Document 701 Filed 07/12/22 Page1of10
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 7, 2021
BY E-MAIL
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 response to the defense letter motion to
preclude testimony by Forensic Examiner Stephen Flatley of the Federal Bureau of Investigation.
There is no reason to exclude any of Flatley’s expected testimony or to delay his cross-
examination. The Government believes that Flatley’s expected testimony does not constitute
expert opinion testimony. However, even if some aspect of his testimony were characterized as
expert opinion, the Government has provided sufficient notice for such testimony and Flatley is
undisputedly qualified to give it. And there is certainly no reason to preclude his testimony based
on the defendant’s late-breaking objection.
I. Factual Background
On September 15, 2021, the Government wrote the defendant a letter notifying her that it
DOJ-OGR-00011180