EFTA00010040.pdf

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pdf

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data-set-8

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U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The SiAdol 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 (MN) 
Dear Judge Nathan: 
The Government respectfully submits this letter seeking clarification on two items from 
the November I, 2021 pretrial conference. 
First, when describing the defendant's ability to cross-examine witnesses who will be 
testifying under pseudonyms, the Court explained that: 
All lines of inquiry the defense outlined in its response are available without 
disclosing specific names of employers or other specifically identifying 
information. For example, the defense can probe the genre, nature, and trajectories 
of witnesses' careers without eliciting the specific employer name, but the defense's 
cross-examination should not include specifically identifying information, and 
counsel must act responsibly doing so. 
(11/01/21 Tr. at 11:20-12:2). The Government seeks clarification before trial about the line 
between permissible and impermissible cross-examination about the "genre" of witnesses' careers. 
Specifically, the Government agrees that the witnesses can be cross examined about their 
professions (e.g. that they are actors), and the general arcs of those careers (e.g. that they had work, 
or they did not; on a TV show or in a movie). (See Gov't Reply ISO Mot. in Limine, Dkt. No. 393, 
EFTA00010040


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at 17-18).1 But there is no "particularized need" to identify the type of movie or TV show (e.g., 
an action movie as opposed to a soap opera). (11/01/21 Tr. at 10:8-11). That information has no 
impeachment value—the notion that an actor works on one type of show rather than another says 
nothing about her credibility. But it creates sig…

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