DOJ-OGR-00011342.jpg

Case 1:20-cr-00330-PAE Document 720 Filed 07/12/22 Page1of3 800 Third Avenue COHEN & GRESSER LLP New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com BY ECF December 14, 2021 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: Pursuant to the Court’s Order of earlier today (Dkt. 542), we write to provide the Court and the government with a revised tentative order of the defense witnesses. We note the following: I. 2064893.1 We are still trying to make travel arrangements for the defense witnesses, many of whom are coming from locations all over the United States and from the United Kingdom. Accordingly, the order below is subject to change. We are making every effort to have witnesses available for Thursday and Friday but, in an abundance of caution, we are informing the Court and counsel that travel and COVID-related issues may require the case to be continued to next week. The list of witnesses may be substantially reduced if the government is willing to agree to stipulations as to certain documents and witness testimony. We have conferred with the government regarding these stipulations, but as yet the government has not agreed to them. Accordingly, the list includes several witnesses who will be called to introduce certain documents or to testify about particular prior inconsistent statements. DOJ-OGR-00011342