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Correspondence

Maxwell defense letter to Judge Nathan opposing witness anonymity rules

Defense attorneys for Ghislaine Maxwell argue the government's proposal for protecting pseudonymous testifying witnesses is overly broad and unworkable.Machine-written summary

Document EFTA 02836040

VIA ECF

The Honorable Alison J. Nathan United States District Court Southern District of New York 4O Foley Square New York, NY 10007

ISO East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpogliucaahmflaw.com

Re: United States v. Ghislathe Maxwell, 20 Cr. 330 (AJN)

Dear Judge Nathan,

I write following our conferral with the government about protecting the anonymity of certain testifying witnesses in this case. The government suggested to us that we must avoid any public mention of: (I) names of people, places, or specific addresses or locations; (2) particular dates of career events or life events; (3) names of any employers, particular performances, or characters played; (4) specific details of story arcs in any performances played; (5) references to publicly available information or publicly available records that contain a pseudonymous witness’s real name; and (6) court filings or other court documents.

Respectfully, the government’s proposal is overly broad and unworkable.

We are mindful of the Court’s orders on this topic, and we have no objection to many of the government’s suggestions—e.g., the names of people or specific addresses or particular employers. But the government’s proposal reaches much too far, and it would unfairly constrain Ms. Maxwell’s ability to meaningfully and effectively confront her accusers. U.S. Const. amend. VI.

Page 2

Not only that, but the government’s direct examination of Jane today would have violated its own proposal—for example, the government elicited testimony about where Jane attended school and during what years, a prime example of a “specific location” and “particular dates of life events” the government now seeks to prevent Ms. Maxwell from eliciting on crossexamination. The government’s proposal is also contrary to this Court’s earlier ruling permitting Ms. Maxwell to confront her accusers by eliciting evidence of their story lines.

We will remain cognizant of our duty to avoid revealing the names of witnesses testifying under pseudonyms. And we will alert the government and the court in advance as we are able to anticipate any issues.

Page 3

Respectfully submitted,

Jeffrey S. Pagliuca

Laura A. Mennin er

HADDON, & P.C.

150 East 10th Avenue

Denver, CO 80203

Phone: 303-831-7364

Christian R. Everclell

& GRESSER LLP

800 Third Avenue

New York, NY 10022

Phone: 212-957-7600

Bobbi C. Sternheim

Law Offices of Bobbi C. Stemheim

225 Broadway, Suite 715

New York, NY 10007

Phone: 212-243-1100

Attorneys for Ghislaine Maxwell

cc: Counsel of record (via ECF)

Maxwell defense letter to Judge Nathan opposing witness anonymity rules

Emails and letters

Defense attorneys for Ghislaine Maxwell argue the government's proposal for protecting pseudonymous testifying witnesses is overly broad and unworkable.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330)

Document EFTA 02836040 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 4O Foley Square New York, NY 10007 ISO East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpogliucaahmflaw.com Re: United States v. Ghislathe Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write following our conferral with the government about protecting the anonymity of certain testifying witnesses in this case. The government suggested to us that we must avoid any public mention of: (I) names of people, places, or specific addresses or …