733.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 2
- Text status
- Searchable text available
- OCR confidence
- 0.8805000411218028
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Pagelof2 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca My 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] HADDON MORGAN FOREMAN November 28, 2021 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 ke United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the government’s letter, dated November 27, 2021, seeking to preclude certain topics of cross- examination.’ The defense does not intend to cross-examine Accuser-1 or Accuser-2 about jy HEE 2 0less their testimony opens the door to such cross-examination. Similarly, the defense does not intend to cross-examine Accuser-1 about EEE 8 olcss the witness’s testimony opens the door to such cross-examination. However, Accuser-1’s brother, who is a testifying witness, told the government less than three weeks go th: lll ' Pursuant to our established protocol, the defense is submitting this letter to the Court under temporary seal to allow the government to propose any appropriate redactions. DOJ-OGR-00011449
Case 1:20-cr-00330-PAE Document 733 Filed 07/14/22 Page2of2 The Honorable Alison J. Nathan November 28, 2021 Page 2 ES The defense should be permitted to cross-examine Accuser-] about yg because it is relevant to her ability to recall the events in question accurately. As the government concedes, it is Respectfully submitted, y— Jeffrey S. Pagliuca CC: Counsel of Record DOJ-OGR-00011450
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