H A D D O N

H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, P C Jeffrey S. Paglluca August 9, 2020 VIA EMAIL Assistant United States Attorney The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 Re: Conferral Concerning Use of Discovery Materials GM_00000847-962 Dear Mr. ell is actively litigating issues related to disclosure of confidential material in v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the above referenced discovery materials which relate to the Government's efforts to obtain civil litigation discovery material ("the Unsealing Materials") in two, settled, civil matters in which Ms. Maxwell was named a defendant. These materials would be disclosed to Judge Preska and designated as part of the appendix to Ms. Maxwell's appeal in the Second Circuit. We have no obj