# Document EFTA 02839287



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 (MN)

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

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 crossexamination.' The defense does not intend to cross-examine Accuser-I or Accuser-2 about= unless their testimony opens the door to such cross-examination. Similarly, the defense does not intend to cross-examine Accuser-1 about unless the witness's testimony opens the door to such cross-examination.

However, Accuser-l's brother, who is a testifying witness, told the government less than three weeks ago that

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.

The Honorable Alison J. Nathan

November 28, 2021

Page 2


[REDACTED] The defense should be permitted to cross-examine Accuser-1 about [REDACTED] because it is relevant to her ability to recall the events in question accurately. As the government concedes, it is

Respectfully submitted,

Jeffrey S. Pagliuca

CC: Counsel of Record