U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Malta Building One Saint Andrew's Plaza New York, New York 10007 October 30, 2020 BY ECF 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, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the defense letter dated October 23, 2020 in the above-referenced case (the "Defense Letter"). For all of its innuendo and accusations, the Defense Letter is at base an effort to preview motions that the Court has already found to be premature and to cast the Government's efforts to be transparent with the Court and the defense in a nefarious and deeply misleading light. The Government writes to correct the inaccuracies in the Defense Letter, to update the Court regarding the status of the Government's ongoing discovery productions, and to address the defense complaints regarding the Metropolitan Detention Center ("MDC"). 1. The Government Has and Will Continue to Satisfy Its Discovery Obligations The Defense Letter raises numerous accusations, including that the Government has "abandon[ed]" the discovery deadlines in this case. (Def. Ltr. I). The Government strongly disagrees, and is prepared to respond in detail to the defendant's various claims and accusations at the appropriate stage. But in short, many of the defense's accusations about the Government's allegedly deficient discovery productions are not only incorrect, but also include complaints that the Court has already directed the defendant to renew only if unable to reach agreement with the Government "[fJollowing the close of discovery," which has not yet passed. (Order dated Aug. 25, 2020, Dkt. 49, at 2). Most notably, the defendant's accusations against the Government rely on a blurring of the line be