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d-7764Court UnsealedLegal Filing

Court Filing: 545

The US Government filed a letter opposing Ghislaine Maxwell's request to call victim lawyers Jack Scarola, Brad Edwards, and Robert Glassman as witnesses, arguing that their testimony is irrelevant and would compromise attorney-client privilege. The Government contends that the victims themselves have already testified and been cross-examined, making the lawyers' testimony unnecessary. The court must decide whether to allow the defendant to call these lawyers as witnesses.

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File: 545
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Summary

The US Government filed a letter opposing Ghislaine Maxwell's request to call victim lawyers Jack Scarola, Brad Edwards, and Robert Glassman as witnesses, arguing that their testimony is irrelevant and would compromise attorney-client privilege. The Government contends that the victims themselves have already testified and been cross-examined, making the lawyers' testimony unnecessary. The court must decide whether to allow the defendant to call these lawyers as witnesses.

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COHEN & GRESSER LLP

COHEN & GRESSER LLP December 10, 2021 BY EMAIL. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case. 1. • 2. 3. 4. 5. 6. 7. 8. Task Force Office 9. Lucy Mary Clive 10. Dr. Park Dietz 2063779.1 EFTA00156482 December 10, 2021 Page 2 11. 12. 13. Brad Edwards (atto

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