EFTA00020815.pdf
97.2 KB
Extraction Summary
6
People
6
Organizations
5
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / discovery letter
File Size:
97.2 KB
Summary
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated October 13, 2021. It accompanies the production of spreadsheets previously reviewed by the defense at an FBI office in Denver. The letter notes that the original spreadsheets contained embedded hyperlinks to images of 'child exploitation materials,' necessitating the creation of a sanitized version for production.
People (6)
| Name | Role | Context |
|---|---|---|
| Damian Williams | United States Attorney |
Sender of the letter, representing the Southern District of New York
|
| Ghislaine Maxwell | Defendant |
Subject of the case United States v. Ghislaine Maxwell
|
| Christian Everdell | Defense Counsel |
Recipient, attorney at Cohen & Gresser LLP
|
| Laura Menninger | Defense Counsel |
Recipient, attorney at Haddon, Morgan and Foreman, P.C.
|
| Jeffrey Pagliuca | Defense Counsel |
Recipient, attorney at Haddon, Morgan and Foreman, P.C.
|
| Bobbi Sternheim | Defense Counsel |
Recipient, attorney at Law Offices of Bobbi C. Sternheim
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Government agency issuing the letter
|
|
| United States Attorney Southern District of New York |
Specific office handling the prosecution
|
|
| FBI |
Federal Bureau of Investigation, location where hard drives were reviewed
|
|
| 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
|
Locations (5)
| Location | Context |
|---|---|
|
Address of the US Attorney's Office
|
|
|
Location of FBI office where hard drives were reviewed and address of defense counsel
|
|
|
Address of Cohen & Gresser LLP
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|
|
Address of Haddon, Morgan and Foreman, P.C.
|
|
|
Address of Law Offices of Bobbi C. Sternheim
|
Relationships (2)
Letter header and subject line 'United States v. Ghislaine Maxwell'
Addressed as counsel in the letter re: Maxwell case
Key Quotes (3)
"The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation materials."Source
EFTA00020815.pdf
Quote #1
"However, the FBI has prepared a version of the spreadsheets you requested without the embedded photographs, which we are producing to you today"Source
EFTA00020815.pdf
Quote #2
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."Source
EFTA00020815.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,518 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 13, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
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:
You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI
office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hard
drives. The Government is not able to provide you with copies of the versions of the spreadsheets
on the hard drives because those spreadsheets are embedded with photographs depicting, among
other things, child exploitation materials. However, the FBI has prepared a version of the
spreadsheets you requested without the embedded photographs, which we are producing to you
today, as listed in the below index. These materials are stamped with control numbers
SDNY_GM_02765031 through SDNY_GM_02765061.
office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hard
drives. The Government is not able to provide you with copies of the versions of the spreadsheets
on the hard drives because those spreadsheets are embedded with photographs depicting, among
other things, child exploitation materials. However, the FBI has prepared a version of the
spreadsheets you requested without the embedded photographs, which we are producing to you
today, as listed in the below index. These materials are stamped with control numbers
SDNY_GM_02765031 through SDNY_GM_02765061.
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,
EFTA00020815
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,
EFTA00020815
Page 2
8, 9, 10, 15, and 17.” This marking directly refers to the specific paragraphs of the Protective
Order that govern today’s production.
Order that govern today’s production.
An index of the materials contained in this production is below:
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02765031 | SDNY_GM_02765061 | Spreadsheets | Confidential
SDNY_GM_02765031 | SDNY_GM_02765061 | Spreadsheets | Confidential
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
by: s/ [REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
[REDACTED]
EFTA00020816
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