Case 1:20-cr-00330-AJN Document 66 Filed 10/23/20 Page 1 of 7 My Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca HADDON MOORS 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmflaw.com [email protected] October 23, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Souther District of New York 40 Foley Square New York, NY 10007 Re: — Response to the Government’s October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, At the initial conference in this case, the Government promised Ms. Maxwell and the Court that it would review and produce “prior investigative files from another investigation in the Southern District of Florida,”! which it characterized as part of “the core of the case” against Ms. Maxwell,” after a “careful and exhaustive and through review of all of the materials,” with the “bulk” of the discovery produced by “the end of this summer [2020].”? Summer is gone, Winter is coming, and the Government has failed to make good on its promises. Although it casts the October 7, 2020 letter to the Court as a “response to the Court’s prior inquiry regarding” its plan to produce discovery, the Government is, in fact, abandoning the deadlines to which it already agreed and reneging on (or redefining) its assurances to the Court that it would engage in “thoughtful and critical pushing and pressing of questions and issues with respect to actively retrieving any appropriate files.”* In fact, the promised “substantial” production of discovery is “substantial” in size, not substance. Approximately one fourth of the production relates to materials gathered in civil litigation to which Ms. Maxwell was a party. The remainder of the discovery contains documents from the 2000s that relate largely to Jeffrey Epstein and therefore have nothing to do with the time period of the conspiracy charged in the ! July14, 2020 Tr. p. 12:20-13. 2 Id., 12:11. 3 Td., 13