EFTA00024791.pdf
95.1 KB
Extraction Summary
8
People
6
Organizations
3
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / discovery production letter
File Size:
95.1 KB
Summary
A discovery production letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated October 28, 2021. The letter lists produced materials including a scanned contact book page, records from the United Kingdom, and materials from the Estate of Jeffrey Epstein, noting confidentiality designations under a protective order.
People (8)
| Name | Role | Context |
|---|---|---|
| Damian Williams | United States Attorney |
Sender of the letter representing the U.S. Department of Justice.
|
| Ghislaine Maxwell | Defendant |
Defendant in the case United States v. Ghislaine Maxwell.
|
| Christian Everdell | Defense Counsel |
Recipient, lawyer at Cohen & Gresser LLP.
|
| Mark Cohen | Defense Counsel |
Recipient, lawyer at Cohen & Gresser LLP.
|
| Laura Menninger | Defense Counsel |
Recipient, lawyer at Haddon, Morgan and Foreman, P.C.
|
| Jeffrey Pagliuca | Defense Counsel |
Recipient, lawyer at Haddon, Morgan and Foreman, P.C.
|
| Bobbi Sternheim | Defense Counsel |
Recipient, lawyer at Law Offices of Bobbi C. Sternheim.
|
| Jeffrey Epstein | Deceased |
Mentioned in the index of materials ('Materials from Estate of Jeffrey Epstein').
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Sender organization.
|
|
| United States Attorney Southern District of New York |
Specific office sending the letter.
|
|
| Cohen & Gresser LLP |
Law firm representing the defense.
|
|
| Haddon, Morgan and Foreman, P.C. |
Law firm representing the defense.
|
|
| Law Offices of Bobbi C. Sternheim |
Law firm representing the defense.
|
|
| Estate of Jeffrey Epstein |
Source of produced materials.
|
Timeline (1 events)
2021-10-28
Production of discovery materials by the DOJ to Ghislaine Maxwell's defense team.
New York, NY
Damian Williams
Ghislaine Maxwell's Defense Team
Locations (3)
| Location | Context |
|---|---|
|
Location of U.S. Attorney's office and defense counsel offices.
|
|
|
Location of Haddon, Morgan and Foreman, P.C.
|
|
|
Source of records listed in the production index.
|
Relationships (2)
Materials from Epstein's estate are being produced in Maxwell's criminal case.
Williams is the U.S. Attorney prosecuting the case against Maxwell.
Key Quotes (4)
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."Source
EFTA00024791.pdf
Quote #1
"Materials from Estate of Jeffrey Epstein"Source
EFTA00024791.pdf
Quote #2
"Records from the United Kingdom"Source
EFTA00024791.pdf
Quote #3
"These materials appear to be largely duplicative of materials previously produced to you in discovery."Source
EFTA00024791.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,583 characters)
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
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 28, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
[Redacted Address]
New York, NY [Redacted Zip]
Mark Cohen, Esq.
Cohen & Gresser LLP
[Redacted Address]
New York, NY [Redacted Zip]
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[Redacted Address]
Denver, CO [Redacted Zip]
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[Redacted Address]
Denver, CO [Redacted Zip]
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
[Redacted Address]
New York, NY [Redacted Zip]
Law Offices of Bobbi C. Sternheim
[Redacted Address]
New York, NY [Redacted Zip]
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02766974.
Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00024791
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02765768 | SDNY_GM_02765768 | Scanned page of contact book | Confidential
SDNY_GM_02765769 | SDNY_GM_02766967 | Materials from Estate of Jeffrey Epstein¹ | Confidential
SDNY_GM_02766968 | SDNY_GM_02766974 | Records from the United Kingdom | Confidential
SDNY_GM_02765768 | SDNY_GM_02765768 | Scanned page of contact book | Confidential
SDNY_GM_02765769 | SDNY_GM_02766967 | Materials from Estate of Jeffrey Epstein¹ | Confidential
SDNY_GM_02766968 | SDNY_GM_02766974 | Records from the United Kingdom | Confidential
The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
by: s/
[Redacted Signature Block]
Assistant United States Attorneys
[Redacted Signature Block]
Assistant United States Attorneys
______________________
¹ These materials appear to be largely duplicative of materials previously produced to you in discovery.
¹ These materials appear to be largely duplicative of materials previously produced to you in discovery.
EFTA00024792
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document