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Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Pagelof2 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.hmflaw.com joagliuca@hmflaw.com HADDON MORGAN FOREMAN 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 (AJN) 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 cross- examination.' The defense does not intend to cross-examine Accuser-1 or Accuser-2 about Jy HE! olcss their testimony opens the door to such cross-examination. Similarly, the defense does not intend to cross-examine Accuser-1 about xs EE 8 oless the witness’s testimony opens the door to such cross-examination. However, Accuser-1’s brother, who is a testifying witness, told the government less than three weeks go th: lll ' 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. DOJ-OGR-00011449