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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ig gues aaneeta Rata .
UNITED STATES OF AMERICA
y. STIPULATION
GHISLAINE MAXWELL, | $220.CR 330 (AIN)
Defendant. :
re x
IT IS HEREBY STIPULATED AND AGREED by and among the United States
of America, by Damian Williams, United States Attorney for the Southern District of New York,
and Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach, Assistant United
States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her
attorneys, Christian Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi
Sternheim, Esq., that:
i On August 17, 2021, Robert Glassman, counsel for the witness testifying
using the pseudonym Jane, spoke by phone with a prosecutor in this case. The notes of the call
reflect that:
ee Glassman stated that before the Government charged the case, Jane had
discussed with Glassman whether to cooperate with the case, and during those conversations
Glassman had advised Jane to cooperate and discussed with Jane that cooperating with the case
was the morally right thing to do, and they had discussed how testifying at trial was the right
thing to do. Glassman also mentioned that Glassman had told Jane it would “help her case.”
S2 20 Cr. 330 (AJN)
Defendant’s Ex. =
DOJ-OGR-00015169