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Case 1:20-cr-00330-PAE Document 331 Cy HADDON MORGAN FOREMAN August 30, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Souther District of New York 40 Foley Square New York, NY 10007 Filed 08/30/21 Pagelof5 Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmilaw.com Re: | Response to Government Letter dated August 18, 2021, Dkt. 320, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write in response to the government’s letter dated August 18, 2021, Dkt. 320, which raises two issues.! Identities of Co-Conspirators The government first attempts to walk back its multiple concessions regarding disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment. As this Court noted, Ms. Maxwell has on at least two occasions requested such disclosure. Dkt. 317 at 12 n.1 (citing Dkt. 291 and Dkt. 293). Only after this Court ordered disclosure of the identities of the unnamed co-conspirators alleged in the S2 indictment did the government finally object. The government’s objection comes too late. ' As directed by the Court, on August 24 the parties conferred about the government’s letter, but they were unable to reach an agreement on the government’s requests for reconsideration. DOJ-OGR-00005019