Case 1:20-cr-00330-AJN Document 62 Filed 10/08/20 Page 1 of 3 U.S. Department of Justice United States Attorney USDC SDNY Southern District of New York || POCUMENT ELECTRONICALLY FILED The Silvio J. Mollo Building DOC #; One Saint Andrew’s Plaza DATE FILED: 10/ 7720 New York, New York 10007 October 6, 2020 BY ECF The Honorable Alison J. Nathan The Defendant shall file any United States District Court SO ORDERED. 10/7/20 | opposition to the Government's Southern District of New York A d 0 Alster request by October 14, 2020. United States Courthouse , The Government's reply, if any, 40 Foley Square Alison J. Nathan, U.S.D J. |is due by October 20, 2020. SO ORDERED. New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to request that the Court grant the Government permission to delay disclosure to the defense of certain photographs of and documents regarding victims of sexual abuse by Jeffrey Epstein. These materials relate to abuse that post- dated the time period charged in the Indictment, and the Government does not intend to offer them at trial. Although the Government intends to produce these materials to the defendant in advance of trial, premature disclosure of these materials could jeopardize the Government’s ongoing investigation and would reveal sensitive victim information months in advance of trial. For these reasons and as set forth below, the Government respectfully submits, pursuant to Federal Rule of Criminal Procedure 16(d)(1), that good cause exists to delay disclosure of these items to defense counsel until eight weeks prior to trial.! The Government has conferred with defense counsel, who have indicated that they object to this request and intend to submit a letter in opposition. As the Court is aware, the superseding indictment in this case (the “Indictment”) charges the defendant in six counts. Count One of the Indictment charges Maxwell with