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Case 1:20-cr-00330-PAE Document 709 Filed 07/12/22 Page1of5 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www. hmilaw.com joagliuca@hmflaw.com HADDON MORGAN FOREMAN November 15, 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 (AJN) Dear Judge Nathan, Pursuant to the Court’s November 1, 2021, Order we write in response to the government's letter of November 12, 2021 to note our good faith objections to categories of alleged co-conspirator hearsay statements and representative examples!: Category 2, “Statements made by Jeffrey Epstein to his employees” appears to relate primarily to statements that post-date any alleged conspiracy. The last overt act alleged in the S-2 ‘In its November 12, 2021 letter to the Court, the government apparently misunderstands, and overstates, its understanding of the Defendant’s position regarding the proffered statements. To be clear, Ms. Maxwell is not agreeing to the admission of any statements proffered by the government under Fed. R. Evid. 801(d)(2)(E) for many reasons including the fact that she was not a member of any conspiracy as alleged in the indictment. Ms. Maxwell understood that, in her conferral letter to the government, she was identifying her good faith objections given established Second Circuit procedures governing the admissibility of the proffered statements. Ms. Maxwell will object, at trial, to any proffered statement when appropriate. DOJ-OGR-00011283