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 in the Government's Daubert motion. EFTA00078462 Page 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) EFTA00078463