EFTA00014889.pdf
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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 27, 2021
REOUEST TO BE FILED UNDER SEAL
BY EMAIL
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 in response to the Court's directive at the
November 23, 2021 final pretrial conference that the Government provide its anticipated order of
witnesses for the upcoming trial in the above-referenced matter.' Consistent with the Court's
instruction, below is the order of witnesses that the Government currently expects to call during
the first two to three days of trial:
2.
3.
4.
testifying under the pseudonym "Jane")
(testifying under the pseudonym "O")
The Government has also attempted to approximate the order in which its remaining
witnesses will testify at trial. The Government notes, however, that this order may change,
' The Government respectfully requests that this letter be filed under seal. Because this letter does
not seek any relief or require any ruling by the Court, it is arguably not a judicial document subject
to the common law presumption of access. Moreover, this letter contains the identities of
witnesses, including witnesses whom the Court has authorized to testify using pseudonyms or their
first names.
EFTA00014889
Page 2
depending on, among other factors, the pace of trial. Many of the below-listed witnesses will be
traveling from out of state, and many witnesses have personal and/or professional obligations
around which the Government is attempting to schedule. Accordingly, it is possible that the
Government may call some of these witnesses in a different order than that indicated below.
Additionally, the Government reser…
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