DOJ-OGR-00011407.jpg

Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 Page1of14 PANISH SHEA & BOYLE LLP December 6, 2021 VIA ECF 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: I am writing on behalf of witness Jane who testified last week at trial in the above- referenced case. I am in receipt of Ms. Maxwell’s motion to compel Jane’s attorney Robert Glassman from my law firm to testify about whether he told Jane that testifying against Ms. Maxwell at this trial would “help her case.” But compelling Mr. Glassman to testify would require him to violate his ethical duties to his client and would offer no relevant information. Accordingly, Ms. Maxwell’s motion must be denied. As a preliminary matter, the subpoena served on Mr. Glassman was improper under Fed. R. Crim. P. 17. But, without waiving the procedural argument, witness Jane would prefer that the matter be decided on the merits to avoid further harassment of her lawyer and risk of exposure of her confidential information.! ' Mr. Glassman was handed a handwritten trial subpoena on December 1, 2021 as he was walking into Your Honor's courtroom to continue to be present for Jane's lengthy cross- examination. (Glassman subpoena is attached hereto as Exhibit 1). That practice seems at a (footnote continued) 11111 Santa Monica Boulevard, Suite 700 * Los Angeles, California 90025 * 310.477.1700 phone * 310.477.1699 fax * www.psblaw.com DOJ-OGR-00011407