EFTA00027296.pdf
98.1 KB
Extraction Summary
6
People
7
Organizations
3
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal correspondence (discovery letter)
File Size:
98.1 KB
Summary
This document is a discovery production letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 4, 2021. It lists produced materials including FBI recovered metadata, Missouri records, a JPMorgan Chase return, and a letter from 1995 related to Oxford. The letter also clarifies new labeling protocols for confidential materials to distinguish them from classified documents.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
|
| Christian Everdell | Defense Counsel |
Recipient, Cohen & Gresser LLP
|
| Mark Cohen | Defense Counsel |
Recipient, Cohen & Gresser LLP
|
| Laura Menninger | Defense Counsel |
Recipient, Haddon, Morgan and Foreman, P.C.
|
| Jeffrey Pagliuca | Defense Counsel |
Recipient, Haddon, Morgan and Foreman, P.C.
|
| Bobbi Sternheim | Defense Counsel |
Recipient, Law Offices of Bobbi C. Sternheim
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Sender, Southern District of New York
|
|
| Cohen & Gresser LLP |
Defense counsel firm
|
|
| Haddon, Morgan and Foreman, P.C. |
Defense counsel firm
|
|
| Law Offices of Bobbi C. Sternheim |
Defense counsel firm
|
|
| FBI |
Source of recovered metadata in discovery index
|
|
| JPMorgan Chase |
Source of financial return records in discovery index
|
|
| Oxford |
Related to a letter dated 11-07-1995 in discovery index
|
Timeline (1 events)
2021-08-04
Production of discovery materials by the US Government to the defense
New York, NY
US Attorney SDNY
Ghislaine Maxwell Defense Team
Locations (3)
| Location | Context |
|---|---|
|
Location of U.S. Attorney's Office and defense counsel offices
|
|
|
Location of defense counsel office
|
|
|
Location related to records produced in discovery
|
Relationships (2)
Everdell is addressed as counsel for the case United States v. Ghislaine Maxwell
Cohen is addressed as counsel for the case United States v. Ghislaine Maxwell
Key Quotes (2)
"This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order."Source
EFTA00027296.pdf
Quote #1
"Recently, 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."Source
EFTA00027296.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (2,492 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
August 4, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Law Offices of Bobbi C. Sternheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02753644 through SDNY_GM_02753697.
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. Recently, 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.
EFTA00027296
Page 2
An index of the materials contained in this production is below:
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02753644 | SDNY_GM_02753692 | FBI Recovered Metadata | Confidential
SDNY_GM_02753693 | SDNY_GM_02753695 | Missouri Records | Confidential
SDNY_GM_02753696 | SDNY_GM_02753696 | JPMorgan Chase Return | Confidential
SDNY_GM_02753697 | SDNY_GM_02753697 | Oxford Letter, 11-07-1995 | Confidential
SDNY_GM_02753644 | SDNY_GM_02753692 | FBI Recovered Metadata | Confidential
SDNY_GM_02753693 | SDNY_GM_02753695 | Missouri Records | Confidential
SDNY_GM_02753696 | SDNY_GM_02753696 | JPMorgan Chase Return | Confidential
SDNY_GM_02753697 | SDNY_GM_02753697 | Oxford Letter, 11-07-1995 | 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,
[REDACTED]
United States Attorney
United States Attorney
by:
[Signature]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
[Signature]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
EFTA00027297
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