U.S. Department of Justice United States Attorney Southern District of New York The Salo ..l. Mao Building One Saint Andrew's Plaza New York New Tont 10007 April 30, 2021 BY ELECTRONIC MAIL Mark Manle Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Manley: The Government writes in response to your letter to the Honorable Alison J. Nathan regarding your client and your request for assurances regarding ensuring your client's anonymity in upcoming criminal proceedings, including in documents or information that identifies your client. As an initial matter, the Government notes that to date, there have been no filings on the public docket in the above-captioned criminal case that name your client. Second, to the extent the Government has produced documents with your client's name to the defense pursuant to its disclosure obligations in this criminal case, those materials have been designated as confidential and are governed by the Protective Order in this case (Dkt. No. 36). Pursuant to the Protective Order, the defense is prohibited from filing publicly any confidential information referenced in the discovery materials, unless authorized by the Government in writing or by order of the Court. The defense has complied with this requirement of the Protective Order and has indicated that it will continue to do SO. As to the upcoming criminal trial in this matter, the Government notes that it does not intend to call your client as a witness at trial. As a courtesy,' we note that your client's name may arise As a general matter, the Government is not obligated to provide a detailed preview to the defense, or third parties, about how it expects to prove its case at trial. EFTA00031609