DOJ-OGR-00008206.jpg

Case 1:20-cr-00330-PAE Document521 Filed 12/03/21 Page1of5 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jeagliuca@hmflaw.com HADDON MORGAN FOREMAN December 3, 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, During her cross-examination, Jane denied knowing that cooperating with the government in the prosecution of Ms. Maxwell and testifying against her would help her civil case against Ms. Maxwell and her claim for compensation from the Epstein Victims’ Compensation Program (EVCP). Because Jane denied having this knowledge, Ms. Maxwell has a constitutional right to call Jane’s attorney (Robert Glassman) as a witness and to ask him whether he told Jane that cooperating and testifying against her would “help her case.” U.S. Const. amends. V, VI. This issue is relevant to Jane’s motive to cooperate and testify,’ and it’s ' Davis v. Alaska, 415 U.S. 308, 316 (1974) (“A more particular attack on the witness’ credibility is effected by means of cross-examination directed toward revealing possible biases, prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities in the case at hand. The partiality of a witness is subject to exploration at trial, and is always relevant as discrediting the witness and affecting the weight of his testimony.” (quotation omitted)). DOJ-OGR-00008206