Case 1:20-cr-00330-AJN Document 511 Filed 11/27/21 Page 1 of 3 LAW OFFICES OF BOBBI C. STERNHEIA\ 212-243-1100 * Main 225 Broadway, Suite 715 917-912-9698 * Cell New York, NY 10007 888-587-4737 ° Fax [email protected] November 27, 2021 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter to request a clarification of the Court’s instructions regarding the use of paper documents versus electronic documents at trial. In particular, the defense is still unclear whether we will be permitted to display documents used for impeachment or refreshing a witness’s recollection in electronic format solely on the video screens used by the witness, the Court, and the Court’s deputy, or whether we will be required to provide paper copies of these materials, even if the materials do not reference a witness who is testifying under a pseudonym. ! The defense is sensitive to the Court and the government’s concerns that people sitting in the gallery of the courtroom do not see any documents that identify the witnesses who are testifying under pseudonyms. We also understand that the Court wants to ensure that the witnesses will have access to the complete documents that may be used for impeachment and refreshing recollection, rather than a ' Counsel for the defense understood the discussion on November 23, 2021, to apply only to documents which contained identifying information for witnesses who are testifying under pseudonyms or first names. The government, however, has suggested that paper documents need to be used for all impeachment and refreshing, whether or not the documents contain such identifying information. DOJ-OGR-00008166