Case 1:20-cr-00330-PAE Document 709 _ Filed 07/12/22 Page1of5
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
My 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmilaw.com
[email protected]
HADDON
MORGAN
FOREMAN
November 15, 2021
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Pursuant to the Court’s November 1, 2021, Order we write in response to the
government's letter of November 12, 2021 to note our good faith objections to categories of
alleged co-conspirator hearsay statements and representative examples!:
Category 2, “Statements made by Jeffrey Epstein to his employees” appears to relate
primarily to statements that post-date any alleged conspiracy. The last overt act alleged in the S-2
‘In its November 12, 2021 letter to the Court, the government apparently
misunderstands, and overstates, its understanding of the Defendant’s position regarding the
proffered statements. To be clear, Ms. Maxwell is not agreeing to the admission of any
statements proffered by the government under Fed. R. Evid. 801(d)(2)(E) for many reasons
including the fact that she was not a member of any conspiracy as alleged in the indictment. Ms.
Maxwell understood that, in her conferral letter to the government, she was identifying her good
faith objections given established Second Circuit procedures governing the admissibility of the
proffered statements. Ms. Maxwell will object, at trial, to any proffered statement when
appropriate.
DOJ-OGR-00011283