Epstein Project

EFTA00014889.pdf

Type
pdf
Source set
data-set-8

Original source

Extracted text

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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