EFTA00040119.pdf

HADDON M OR C A N FOREMAN November 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York I St. Andrew's Plaza New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 Eost lath Avenue Denver, Co PH FX www hmflaw corn Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Defendant's Good Faith, Non-Frivolous Objections to Proffered Co-Conspirator Hearsay Statements Dear Counsel, Pursuant to the Court's November 1, 2021 Order we write to note our good faith objections to certain categories of alleged co-conspirator hearsay statements, and representative examples: Regarding the first, third, and fourth' designated categories, there are two issues for conferral. First, we assume that these proffered statements are limited to those individuals specifically identified by the government as "minor victims" in the indictment or correspondence to defense counsel dated October 11, 2021. There were many alleged minor victims in the Southern Florida state and federal investigations. To the extent that the government intends to include statements made to other alleged "minor victims" not specifically identified, Ms. "Statements made by Epstein to friends and Family of Minor Victims," "Statements made by CC-2 to friends and Family of Minor Victims," and "Statements made by Jeffrey Epstein to the Minor Victims or in their presence." EFTA00040119