Case 1:20-cr-00330-PAE Document 720 Filed 07/12/22 Page1of3
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COHEN & GRESSER LLP New York, NY 10022
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Christian R. Everdell
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BY ECF
December 14, 2021
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, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
Pursuant to the Court’s Order of earlier today (Dkt. 542), we write to provide the Court
and the government with a revised tentative order of the defense witnesses. We note the
following:
I.
2064893.1
We are still trying to make travel arrangements for the defense witnesses, many of
whom are coming from locations all over the United States and from the United
Kingdom. Accordingly, the order below is subject to change. We are making every
effort to have witnesses available for Thursday and Friday but, in an abundance of
caution, we are informing the Court and counsel that travel and COVID-related issues
may require the case to be continued to next week.
The list of witnesses may be substantially reduced if the government is willing to agree
to stipulations as to certain documents and witness testimony. We have conferred with
the government regarding these stipulations, but as yet the government has not agreed
to them. Accordingly, the list includes several witnesses who will be called to
introduce certain documents or to testify about particular prior inconsistent statements.
DOJ-OGR-00011342