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Case 1:20-cr-00330-PAE Document 234 Filed 04/22/21 Page1lof5 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmilaw.com jpagliuca@hmilaw.com HADDON MORGAN FOREMAN April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Response to Dkt. No. 227, Government’s April 21, 2021 Letter re Ms. Maxwell’s Motions to Suppress Dear Judge Nathan: We write in response to the government’s letter about Ms. Maxwell’s pending motions to suppress and request for evidentiary hearing (Dkt. No. 227), and this Court’s order stating an intent to defer resolution of those motions and that request until after the trial on the non- perjury counts (Dkt. No. 231). Although we appreciate the need to streamline the pretrial process and the desire to efficiently resolve the pending disputes, we do not agree that the government’s letter provides an adequate basis to defer resolution of Ms. Maxwell’s motions. We understand the Court’s desire to maintain the status quo relating to the defense motions, but the government’s response gives Ms. Maxwell no confidence that the government shares this understanding. Indeed, the government’s vague assurances are insufficient to safeguard Ms. Maxwell’s constitutional rights, to guarantee the government will not benefit from its unconstitutional conduct, and to ensure that Ms. Maxwell’s is not deprived of due process through the introduction and use of evidence that itself was obtained in violation of due process. DOJ-OGR- 00003938