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December 10, 2021



United States Attorney’s Office Southern District of New York
1 St. Andrew’s Plaza
New York, NY 10007

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

Dear Counsel:

Pursuant to the Court’s Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court’s instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case.



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December 10, 2021
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In the email accompanying this letter, we have also provided a hyperlink to a Sharefile containing the defense disclosures under Rule 26.2.

Sincerely,



/s/ Christian R. Everdell

Christian R. Everdell

COHEN & GRESSER LLP

800 Third Avenue, 21st Floor

New York, New York 10022



cc: All counsel of record (by email)

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