Cétasbh: 2Q20rOCRRSP AON Demument220 AréelOes16y221 Pategt afef 4 Uspc SDNY DOCUMENT ELECTRONICALLY FILED U.S. Department of Justice DOC #: ; DATE FILED: 8/19/21 United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza OE in tink PO The parties are hereby ORDERED to meet and confer in an effort to reach an agreement on the VIA ECF The Honorable Alison J. Nathan August 18, 2021 disclosure issues raised in this United States District Court Southern District of New York letter. If the parties reach an United States Courthouse A \) iif agreement, they shall inform the 40 Foley Square eo CURRED: 8/19/21 Court by August 26, 2021. If the New York, New York 1 0007 ALISON J. NATHAN, U.S.DJ. parties do not reach agreement, the Defendant may file a response to the arguments made here by the Government on or before August Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) |39- 2921. Any response letter shall confirm that the meet and confer Dear Judge Nathan: occurred. SOORDERED. The Government respectfully submits this letter in response to footnote 1 of the Court’s Opinion and Order denying the defendant Ghislaine Maxwell’s supplemental pretrial motions. (Dkt. No. 317). In that footnote, the Court noted that the defendant’s motion for a bill of particulars included a request that the Government identify her unnamed co-conspirators, as did her position in the parties’ joint letter regarding the disclosure schedule. The Court wrote that, because the Government had not objected, it “presumes the Government intends to disclose this information to Maxwell at the same time that . . . it discloses Jencks Act material.” (/d. at 12 n.1). To be clear, the Government objects to any requirement that it provide an exhaustive list of co-conspirators, whether in a bill of particulars or otherwise, and does not intend to do so absent further order of the Court. ! ' The Government has opposed the defendant’s requests fo