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Case 1:20-cr-00330-AJN Document 42 Filed 08/17/20 Page1of5 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen@cohengtesset.com Christian R. Everdell +1 (212) 957-7600 cevetdell@cohengresset.com August 17, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse AO Foley Square New York, New York 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 to reply to the government’s letter, dated August 13, 2020, responding to Ms. Maxwell’s request that the Court (i) direct the government to disclose the identities of the three alleged victims referenced in the indictment, subject to the restrictions of the protective order in this case; and (i1) order the Bureau of Prisons (“BOP”) to provide Ms. Maxwell with increased access to the discovery materials (“Government’s Response” or “Gov’t Resp.”) (Dkt. 41). With regard to the issue of alleged victims’ identities, the government concedes, as it must, that this Court has the authority and discretion to order the relief sought, but claims that Ms. Maxwell’s application should be denied as untimely and without merit. (Gov’t Resp. at 2- 4). Instead, the government asserts that the appropriate and timely way for Ms. Maxwell to seek confirmation of their identities is through a request for a bill of particulars, which should be filed in December 2020. (/d. at 3). The government then notes that it would oppose such a motion, which it claims should also be denied. (/d.). The government concludes that it will finally provide confirmation of their identities in the 3500 material and a witness list to be provided shortly before trial. (/d. at 4). The upshot of this is clear: in the government’s view, Ms. Maxwell should not know the identity of the three witnesses referenced in the indictment until at best just before trial, and should have to spend the next eleven months (or longer) trying to conduct a defense investigation, in a case in which she is presumed innocent, without having this information. This information is critical to conducting a meaningful defense investigation, given that the DOJ-OGR-00001724