Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Pagelof2
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.hmflaw.com
[email protected]
HADDON
MORGAN
FOREMAN
November 28, 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,
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response
to the government’s letter, dated November 27, 2021, seeking to preclude certain topics of cross-
examination.' The defense does not intend to cross-examine Accuser-1 or Accuser-2 about Jy
HEE! oless their testimony opens the door to such cross-examination. Similarly, the
defense does not intend to cross-examine Accuser-1 about as
HE 8 oless the witness’s testimony opens the door to such cross-examination.
However, Accuser-1’s brother, who is a testifying witness, told the government less than
three weeks go th: lll
' Pursuant to our established protocol, the defense is submitting this letter to the Court
under temporary seal to allow the government to propose any appropriate redactions.
DOJ-OGR-00011449