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Case 1:20-cr-00330-PAE Document 227 Filed 04/21/21 Page1of3 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 April 21, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court’s Order dated April 19, 2021, which directed the Government to notify the Court whether it intends to “use any of the documents subject to the pending motions to suppress in the trial of the non-perjury counts in this case.” (Dkt. No. 216). As an initial matter, the Government strongly opposes the defendant’s suppression motions, and the Government respectfully submits that the Court should deny the motions on the merits without an evidentiary hearing. However, in the interest of efficiency, and with the goal of streamlining matters in advance of trial, the Government respectfully submits that the Court need not resolve the pending suppression motions in advance of the trial on the non-perjury counts. Resolution of the suppression motions is not necessary at this juncture, because, after considering the matter, the Government does not intend to use these materials in its case-in-chief at the trial of the non-perjury counts in this case. However, the Government notes that the materials DOJ-OGR-00003918