DOJ-OGR-00006963.jpg

_ Case 1:20-cr-00330-PAE Document 457 Filed 11/13/21 Page1of8 pace U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 12, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter regarding Government Exhibit 52, a contact book belonging to the defendant, which includes contact information for ee. At the November 1, 2021 conference, the Court requested additional briefing regarding this evidence. The defense has moved to preclude this evidence, arguing that it cannot be authenticated. (Dkt. No. 390). For the reasons set forth below, the defense is incorrect. Testimony at trial will establish that Government Exhibit 52 is in fact a contact book that belonged to the defendant, and the fact that the defendant kept contact information for FS ee: compelling evidence of her guilt. This evidence should be admitted. I. Background Government Exhibit 52 is a printed, bound contact book, containing dozens of pages of contacts, including family and friends of the defendant. The entire book is marked for identification as Government Exhibit 52, and the Government anticipates asking a witness at trial about the book—specifically, an individual who worked for Jeffrey Epstein (“Employee-1’). However, the Government does not intend to offer the full contact book in evidence. Instead, the DOJ-OGR-00006963