EFTA00022052.pdf
117 KB
Extraction Summary
6
People
8
Organizations
4
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / discovery production letter
File Size:
117 KB
Summary
A discovery production letter dated October 19, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter outlines a production of evidence including FBI Florida and NY documents, Palm Beach Police Department (PBPD) materials, aerial video, and 3-D blueprints, spanning Bates numbers SDNY_GM_00328070 through SDNY_GM_00356148. The letter designates specific items as 'Confidential' or 'Highly Confidential' under a Protective Order.
People (6)
| Name | Role | Context |
|---|---|---|
| Audrey Strauss | Acting United States Attorney |
Sender of the letter representing the Government
|
| 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.
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell)
|
Organizations (8)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Header organization
|
|
| United States Attorney Southern District of New York |
Prosecuting office
|
|
| Cohen & Gresser LLP |
Defense law firm
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|
| Haddon, Morgan and Foreman, P.C. |
Defense law firm
|
|
| FBI |
Federal Bureau of Investigation, source of evidence documents
|
|
| PBPD |
Palm Beach Police Department (implied), source of evidence materials
|
|
| PBSA |
Source of evidence materials (likely Palm Beach State Attorney or similar)
|
|
| SDFL |
Southern District of Florida (implied), source of evidence materials
|
Locations (4)
| Location | Context |
|---|---|
|
US Attorney's Office address
|
|
|
Cohen & Gresser LLP address
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|
Haddon, Morgan and Foreman, P.C. address
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|
Location related to FBI documents and video investigation evidence
|
Relationships (2)
Letter from US Attorney regarding US v. Ghislaine Maxwell
Addressed as Counsel in US v. Ghislaine Maxwell
Key Quotes (4)
"In recognition of the Government’s ongoing discovery obligations, today we are producing copies of the materials listed in the below index"Source
EFTA00022052.pdf
Quote #1
"The password for the drive is [REDACTED]"Source
EFTA00022052.pdf
Quote #2
"Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case."Source
EFTA00022052.pdf
Quote #3
"This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order."Source
EFTA00022052.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (3,543 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 19, 2020
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
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government’s ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_00328070 through SDNY_GM_00356148. The password for the drive is [REDACTED]. The materials are available for pickup at the U.S. Attorney’s Office in Manhattan.
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. An index of the materials contained in this production is below:
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_00328070 | SDNY_GM_00328072 | 2020.07.02, Aerial Video |
SDNY_GM_00328073 | SDNY_GM_00328092 | FBI Florida Documents | Confidential
SDNY_GM_00328093 | SDNY_GM_00328289 | FBI NY Documents |
SDNY_GM_00328290 | SDNY_GM_00328461 | Misc. Photos | Confidential
SDNY_GM_00328070 | SDNY_GM_00328072 | 2020.07.02, Aerial Video |
SDNY_GM_00328073 | SDNY_GM_00328092 | FBI Florida Documents | Confidential
SDNY_GM_00328093 | SDNY_GM_00328289 | FBI NY Documents |
SDNY_GM_00328290 | SDNY_GM_00328461 | Misc. Photos | Confidential
1 Files in PDF format designated as “confidential” under the protective order have been stamped “confidential.” However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. Such files include in their electronic names the word “Confidential.”
06.20.2018
EFTA00022052
EFTA00022052
Page 2
SDNY_GM_00328462 | SDNY_GM_00328667 | PBPD Materials |
SDNY_GM_00328668 | SDNY_GM_00329968 | PBPD Materials | Confidential
SDNY_GM_00329969 | SDNY_GM_00330052 | PBPD Materials | Highly Confidential
SDNY_GM_00330053 | SDNY_GM_00332355 | PBSA Materials | Confidential
SDNY_GM_00332356 | SDNY_GM_00332436 | Scans of FBI Evidence |
SDNY_GM_00332437 | SDNY_GM_00332863 | Scans of FBI Evidence | Confidential
SDNY_GM_00332864 | SDNY_GM_00332869 | Scans of FBI Evidence | Highly Confidential
SDNY_GM_00332870 | SDNY_GM_00332871 | Video from Florida Investigation | Highly Confidential
SDNY_GM_00332872 | SDNY_GM_00332887 | Videos from Florida Investigation | Confidential
SDNY_GM_00332888 | SDNY_GM_00332890 | SDFL Materials | Confidential
SDNY_GM_00332891 | SDNY_GM_00332891 | SDFL Materials | Highly Confidential
SDNY_GM_00332892 | SDNY_GM_00332894 | FBI Florida Documents |
SDNY_GM_00332895 | SDNY_GM_00332928 | FBI FL Documents (included with 328073-328092) | Confidential
SDNY_GM_00332943 | SDNY_GM_00332958 | 3-D Blueprints, in PBPD Materials (included with 328462-328667) |
SDNY_GM_00332949 | SDNY_GM_00356148 | FBI FL Documents from Discs | Confidential and Highly Confidential
SDNY_GM_00328668 | SDNY_GM_00329968 | PBPD Materials | Confidential
SDNY_GM_00329969 | SDNY_GM_00330052 | PBPD Materials | Highly Confidential
SDNY_GM_00330053 | SDNY_GM_00332355 | PBSA Materials | Confidential
SDNY_GM_00332356 | SDNY_GM_00332436 | Scans of FBI Evidence |
SDNY_GM_00332437 | SDNY_GM_00332863 | Scans of FBI Evidence | Confidential
SDNY_GM_00332864 | SDNY_GM_00332869 | Scans of FBI Evidence | Highly Confidential
SDNY_GM_00332870 | SDNY_GM_00332871 | Video from Florida Investigation | Highly Confidential
SDNY_GM_00332872 | SDNY_GM_00332887 | Videos from Florida Investigation | Confidential
SDNY_GM_00332888 | SDNY_GM_00332890 | SDFL Materials | Confidential
SDNY_GM_00332891 | SDNY_GM_00332891 | SDFL Materials | Highly Confidential
SDNY_GM_00332892 | SDNY_GM_00332894 | FBI Florida Documents |
SDNY_GM_00332895 | SDNY_GM_00332928 | FBI FL Documents (included with 328073-328092) | Confidential
SDNY_GM_00332943 | SDNY_GM_00332958 | 3-D Blueprints, in PBPD Materials (included with 328462-328667) |
SDNY_GM_00332949 | SDNY_GM_00356148 | FBI FL Documents from Discs | Confidential and Highly 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 or if you wish to arrange a time to review physical items in the FBI’s custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
Acting United States Attorney
by: [REDACTED SIGNATURE BLOCK]
Assistant United States Attorneys
Assistant United States Attorneys
06.20.2018
EFTA00022053
EFTA00022053
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