EFTA00024222

EFTA00028257

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under

EFTA00010037

EFTA00023217

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 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 (AJN) Dear Judge Nathan: The Government respectfully requests permission to file a reply brief in support of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the defendant's opposition brief raises new arguments about hearsay exceptions that the defendant argues apply to information contained in Dr. Hall's report and further elaborates on the defendant's theory of the report's relevance. The Government proposes to file its responsive brief by noon on November 22, 2021, and to respond only regarding Dr. Hall and not the other experts discussed

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 28, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records design