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Case 1:20-cr-00330-PAE Document 188 Filed 03/29/21 Page 1 of 5

U.S. Department of Justice

United States Attorney
Southern District of New York

The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

March 29, 2021

BY ECF

The Honorable Alison J. Nathan
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007

Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)

Dear Judge Nathan:

The Government writes to notify the Court that today, a Grand Jury sitting in Manhattan returned a superseding indictment in the above-captioned case (the “S2 Indictment”).¹ The Government respectfully submits this letter (1) to identify the differences between the charges contained in the S2 Indictment and the charges contained in the prior indictment, S1 20 Cr. 330 (AJN) (the “S1 Indictment”); (2) to address the impact, if any, of the S2 Indictment on the status of discovery and other disclosures; and (3) to address the impact of the S2 Indictment on the currently pending motions.

¹ The Government noted in its February 26, 2021 Omnibus Memorandum of Law in Opposition to the Defendant’s Pretrial Motions that its investigation remained ongoing and that the Government would seek a superseding indictment no later than three months prior to trial. At this juncture, while the Government’s investigation is still ongoing, if trial remains set for July 12, 2021 as scheduled, then the Government does not intend to seek any further indictments in this case. To the extent the Government uncovers additional evidence that it may seek to introduce at trial, it will promptly disclose such evidence to the defense as either Rule 16 or Jencks Act material. Additionally, the Government remains cognizant that its Brady obligations remain ongoing and will promptly disclose any exculpatory evidence of which it becomes aware.

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