713 [DOJ-OGR-00011300—DOJ-OGR-00011303]

Case 1:20-cr-00330-PAE Document 713 Filed 07/12/22 Page1of4 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 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 writes in opposition to the defendant’s motion for an arrest warrant for Kelly Bovino. It is not clear that Bovino is under subpoena for the same reasons Robert Glassman has previously articulated.! Assuming she is, however, the defense letter correctly states that the Court “has authority” to issue an arrest warrant. (Def. Letter at 2-3). But the Court is not required to do so, and in this case, the Court should exercise its discretion to not sign the arrest warrant. The defendant has been aware of the 3500 material that forms the basis of the defendant’s ' The defense subpoena was served on November 30, 2021, (see Def. Letter Ex. 2), but it required her to appear at the United States Courthouse at 9:00 a.m. on November 29, 2021 (see id. Ex. 1)— an impossibility. The defense has cited no law for the proposition that Bovino has refused to “comply with an order of the court to testify,” 28 U.S.C. § 1826, by failing to comply with a subpoena with which she could never have complied. 1 DOJ-OGR-00011300