COHEN & GRESSER LLP

COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-76IX) ccvcrdc11@colungresscr.com December 10, 2021 BY EMAIL nited tates Attorney's O ice 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. 2. Richard Barnett r. ar le z 2063779.1 EFTA00155647 December Iu, Page 2 II. Ryan Dionne 12. 13. Brad