C0HEN & GRESSER LLP

CL C0HEN & GRESSER LLP Christian R. Everdell +1 _12 957-76IXI November 8, 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 defense's disclosures under Rule 16(b)(1)(A) and (b)(1)(B) of the Federal Rules of Criminal Procedure. As the government is aware, the defense is under no obligation to present a defense case and whether we will do so remains subject to the developments at trial. Nevertheless, in accordance with the Court's order, we provide below a preliminary list of documents that the defense may use in its case-in-chief, should we decide to present a defense case. We note that Rule 16(b)(1)(A) requires disclosure only of documents and other items that are "within the defendant's possession, custody, or control; and .