Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 1 of 6

Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 Page 1 of 6 SOO Third 4wnw COHEN & GRESSER LLP October 14, 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, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, in opposition to the government's October 6, 2020 letter requesting the Court's permission to delay the disclosure of photographs and documents relating to certain alleged victims of sexual abuse by Jeffrey Epstein (the "Materials"), pursuant to Rule 16(d)(1) of the Federal Rules of Criminal Procedure. (Dkt. 60). The government's request should be denied for two reasons. First, it is clear from the government's letter that the Materials pertain to individuals who claim to have been "sexually abused by [Jeffrey] Epstein" (id. at 2), but who have not accused Ms. Maxwell of par