Case 1:20-cr-00330-PAE Document 701 Filed 07/12/22 Page1of10 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 December 7, 2021 BY E-MAIL 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, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the defense letter motion to preclude testimony by Forensic Examiner Stephen Flatley of the Federal Bureau of Investigation. There is no reason to exclude any of Flatley’s expected testimony or to delay his cross- examination. The Government believes that Flatley’s expected testimony does not constitute expert opinion testimony. However, even if some aspect of his testimony were characterized as expert opinion, the Government has provided sufficient notice for such testimony and Flatley is undisputedly qualified to give it. And there is certainly no reason to preclude his testimony based on the defendant’s late-breaking objection. I. Factual Background On September 15, 2021, the Government wrote the defendant a letter notifying her that it DOJ-OGR-00011180