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Case 1:20-cr-00330-PAE Document 267 Filed 05/03/21 Page1of7 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.hmflaw.com jpagliuca@hmflaw.com HADDON MORGAN FOREMAN May 3, 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) Joint Letter re. defense witness disclosures, Dkt. No. 250 Dear Judge Nathan: Pursuant to your order of April 26, 2021, Dkt. No. 250, the respective positions of the parties regarding the timing of any defense Fed. R. Crim. P. 26.2 disclosures are set forth below. Ms. Maxwell’s Position Ms. Maxwell does not agree with the government’s proposal that she submit witness statements pursuant to Federal Rule of Criminal Procedure 26.2 at least four weeks in advance of trial. No statute or rule requires disclosure of either non-expert witness lists or Rule 26.2 material in advance of trial. Furthermore, the defense has not been given any specific dates related to any alleged illegal activity nor has the government disclosed the actual identity of any alleged victim or witness. Accordingly, it is impossible to identify any affirmative witness who might, for example, place Ms. Maxwell in a different location at a specific date and time. Until the government completes the presentation of its evidence at trial, the defendant will not be able to identify definitively witnesses that may be relevant or necessary. A court order for pretrial DOJ-OGR-00004084