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_ Cabase: 2@2OrOCRREBP AGN Decuria. 9 Atéehniny(py71 Patpye afaf 3 = U.S. Department of Justice United States Attorney Southern District of New York USDC SDN¥ — " The Silvio J. Mollo Building ‘ st One Saint Andrew’s Plaza DOCUMENT New York, New York 10007 ELECTRONICALLY FILED DOC #; DATE FILED: 1 November 4, 2021 BY ECF The Court hereby DENIES the Government's request as to Dr. Park Dietz and Dr. Elizabeth Loftus. Pursuant to this Court's Order, if the The Honorable Alison J. Nathan | Government seeks to exclude these anticipated witnesses, briefing must United States District Court be submitted by November 8, 2021. Dkt. No. 409. As to the remaining Southern District of New York individuals disclosed in Defendant's notice, the Court GRANTS the United States Courthouse Government's request. If the Government seeks to exclude those 40 Foley Square anticipated witnesses, briefing must be submitted by November 15, 2021, New York, New York 10007 with a response by Defendant due November 19, 2021. SO ORDERED. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) AN i i Dear Judge Nathan: 11/4/21 The Government respectfully moves for reconsideration of the portions of the Court’s order dated November 3, 2021 (Dkt. No. 409), directing the Government to file by November 8, 2021, any briefing to exclude any defense witness testimony disclosed on November 1, 2021, with defense responses due November 11, 2021. This schedule provides the Government seven days—or six, if timed from the Court’s order—to respond to the defense’s expert notice, in which they gave notice for the first time of eight potential experts. By contrast, the Government notes that it provided the defense with notice of its expert on April 23, 2021, and the defense filed its motion to preclude on October 18, 2021.1 Moreover, during that time, the Government will be (1) preparing for the November 10, 2021 Daubert hearing; (2) responding to the defendant’s motion for reconsideration regarding disclosure of juror names (Dkt. No. 407); (3) providing the defense with categories of its co- conspirator statements and exemplars; (4) briefing the admissibility of Minor Victim-3’s testimony ' The Government also provided expert notice of a witness who it does not believe requires admission through Rule 702 on September 15, 2021. The defense has not moved to preclude that witness. DOJ-OGR-00006169