HADDON

HADDON MORGAN FOREMAN November 27, 2021 United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon. Morgan and Foreman, Pc Laura A. Menninger www.hmftaw.com I write pursuant to the Court's Order of November 23, 2021 directing a supplement to the disclosure for Certified Forensic Examine expert opinion to the extent he intends to offer rebuttal testimony to any opinions offered in the government's original disclosure for Stephen Flatley, dated September 15, 2021. I note that yesterday you provided a supplemental notice for Mr. Flatley. That supplement was untimely. Thus, we intend to object at trial to the admission of any opinions from Mr. Flatley not included in your September 15, 2021 disclosure. This supplement for Mr. does not purport to respond to anything contained in your Flatley supplement. We anticipate that Mr. will testify about the meaning of certain pieces of metadata as