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Case 1:20-cr-00330-PAE Document 358 _ Filed 10/18/21 Page1of4 My) Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca HADDON MOOR CN 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmilaw.com October 18, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Today, counsel for Ghislaine Maxwell filed 13 motions in /imine and accompanying exhibits seeking the following relief: to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order; to Exclude Any Evidence Offered by the Government Pursuant to Fed. R. Evid. 404(b) for Failure to Comply with the Rule's Notice Requirement; to Exclude Under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) and Request for Daubert Hearing; to Exclude Evidence Related to Accuser-3; to Exclude Evidence of Alleged Flight; to Exclude Evidence of Ms. Maxwell's Alleged False Statements and to Redact Allegations Related to the Perjury Counts from the Second Superseding Indictment; DOJ-OGR-00005260