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Case 1:20-cr-00330-AJN Document 43 Filed 08/17/20 Page 1 of 1 My) Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca HADDON MORGAN 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmflaw.com jpagliuca@hmilaw.com August 17, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Souther District of New York 40 Foley Square New York, NY 10007 Re: Request for Permission to Submit Letter Motion in Excess of Three Pages United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Pursuant to your Revised Individual Practices in Criminal Cases, specifically Practice 2.B, we request permission to exceed the three-page limitation and submit contemporaneously to chambers the letter motion (“motion,”) under seal, which is eight pages, exclusive of the attachments. We felt that a substantial amount of background and factual information was necessary to place the relief requested in the motion into context. Counsel for Ms. Maxwell spent considerable time editing the motion to eliminate extraneous information and present the motion as succinctly as possible. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) DOJ-OGR-00001729