The document is a letter from the U.S. Department of Justice to Judge Alison J. Nathan arguing again...

Court Filing: 715

The defense is objecting to the government's late disclosure of expert opinion testimony by Stephen Flatley, arguing that it was untimely and should be precluded. The government had previously claimed Flatley would only offer fact testimony, but the defense argues that the November 26, December 3, and December 5 disclosures reveal expert opinion testimony.

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 14, 2021 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 (AJN) Dear Judge Nathan: The parties respectfully submit this joint letter to provide the Court with a list of names, places, and relevant entities, for purposes of examining prospective jurors during voir dire. This letter is respectfully requested to be filed under seal to protect the privacy of witnesses and third parties. I. List of Names The following is a list of names that jurors may hear at trial: • Juan Alessi • Maria Alessi • • Janusz Banasiak • • Daniel Besselsen • • • • Michael Buscemi EFTA00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz

EFTA01659105

The letter from the U.S. Attorney's Office to defense counsel outlines the expected testimony of Com...

The letter from the U.S. Attorney's Office to defense counsel outlines the expected testimony of Computer Forensic Examiner Stephen Flatley regarding his analysis of digital devices and metadata. Flatley's testimony is expected to cover the forensic examination of devices, the process of creating 'clones' of digital media, and the analysis of metadata associated with certain files. The government asserts that Flatley's testimony is based on his first-hand knowledge and does not require expert testimony under Rule 702 of the Federal Rules of Evidence.

EFTA Document EFTA01659105

EFTA Document EFTA01653661