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Court filing · Dec. 13, 2021

SDNY letter to Judge Nathan opposing a stipulation on testimony, Dec. 2021

Government letter in United States v. Maxwell declining a stipulation on counsel's testimony about a privilege issue, citing inadmissibility.Machine-written summary

Document EFTA 02836199

U.S. Department of Justice

United States Attorney Southern District of New York

The Silvio J. Mob Building One Saint Andrew’s Plaza New York New Yoth 10007

December 13, 2021

BY ECF

The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007

Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)

Dear Judge Nathan:

The Government respectfully submits this letter regarding the question whether the pending privilege issue could be resolved by a stipulation regarding the testimony of Robert Glassman. After considering the issue and conferring with defense counsel, the Government remains of the view that the statement in the email is not admissible and requires additional context for it to be understandable by the jury. (See Gov’t Letter at 7-8, Dkt. No. 528; 12/6/21 Letter from Robert Glassman at 3-4). Accordingly, the Government would not enter into such a stipulation.

Respectfully submitted,

DAMIAN United States Attorney

By: sl Maurene Convey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York

Cc: Defense Counsel (by ECF)

SDNY letter to Judge Nathan opposing a stipulation on testimony, Dec. 2021

Court filings

Government letter in United States v. Maxwell declining a stipulation on counsel's testimony about a privilege issue, citing inadmissibility.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · Dec. 13, 2021

Document EFTA 02836199 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York New Yoth 10007 December 13, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter regarding the question whether the pending privilege issue could be resolved by a stipulation regarding the testi…