DOJ-OGR-00008206.pdf

--- Page 1 --- **Document Extraction** **Case Information** * Case Number: 1:20-cr-00330-PAE * Document Number: 521 * Filed Date: 12/03/21 **Header** * **Haddon, Morgan and Foreman, P.C.** * **Jeffrey S. Pagliuca** * **150 East 10th Avenue** * **Denver, Colorado 80203** * **PH 303.831.7364** * **FX 303.832.2628** * **www.hmflaw.com** * **jpagliuca@hmflaw.com** **Letterhead** * **Haddon Morgan Foreman** * **Haddon Morgan Foreman** **Date** * December 3, 2021 **VIA ECF** * The Honorable Alison J. Nathan * United States District Court * Southern District of New York * 40 Foley Square * New York, NY 1007 **Re:** * United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) **Dear Judge Nathan,** * During her cross-examination, Jane denied knowing that cooperating with the government in the prosecution of Ms. Maxwell and testifying against her would help her civil case against Ms. Maxwell and her claim for compensation from the Epstein Victims' Compensation Program (EVCP). Because Jane denied having this knowledge, Ms. Maxwell has a constitutional right to call Jane's attorney (Robert Glassman) as a witness and to ask him whether he told Jane that cooperating and testifying against her would "help her case." U.S. Const. amends. V, VI. This issue is relevant to Jane's motive to cooperate and testify, and it's **1 Davis v. Alaska, 415 U.S. 308, 316 (1974) ("A more particular attack on the witness' credibility is effected by means of cross-examination directed toward revealing possible biases, prejudices, or ulterior motives of the witness as they may relate directly to issues or personalities in the case at hand. The partiality of a witness is subject to exploration at trial, and is always relevant as discrediting the witness and affecting the weight of his testimony." (quotation omitted))** **Page 1 of 5**