EFTA00010180.pdf

93.6 KB

Extraction Summary

6
People
8
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence (discovery production letter)
File Size: 93.6 KB
Summary

A discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 11, 2021. The letter details the production of 'Amazon records' (Bates SDNY_GM_02771981-02771983) which were sourced from the U.S. Attorney's Office for the Southern District of Florida and potentially duplicate materials previously produced from the Florida FBI file.

People (6)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the case United States v. Ghislaine Maxwell
Christian Everdell Defense Counsel
Recipient of the letter, Cohen & Gresser LLP
Mark Cohen Defense Counsel
Recipient of the letter, Cohen & Gresser LLP
Laura Menninger Defense Counsel
Recipient of the letter, Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca Defense Counsel
Recipient of the letter, Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim Defense Counsel
Recipient of the letter, Law Offices of Bobbi C. Sternheim

Organizations (8)

Name Type Context
U.S. Department of Justice
Sender organization
United States Attorney Southern District of New York
Prosecuting office
Cohen & Gresser LLP
Defense law firm
Haddon, Morgan and Foreman, P.C.
Defense law firm
Law Offices of Bobbi C. Sternheim
Defense law firm
Amazon
Subject of the records being produced (Amazon records)
FBI
Mentioned regarding the Florida FBI file
U.S. Attorney’s Office for the Southern District of Florida
Source of the files being produced

Timeline (2 events)

2020-07-31
Protective Order issued governing the case.
New York, NY
2021-11-11
Production of discovery materials (Amazon records) by the DOJ to Ghislaine Maxwell's defense team.
New York, NY
DOJ Defense Counsel

Locations (2)

Location Context
Location of the U.S. Attorney's Office sending the letter
Location of the FBI file and U.S. Attorney's Office where records were stored

Relationships (2)

Ghislaine Maxwell Attorney-Client Christian Everdell
Letter addressed to Everdell regarding United States v. Ghislaine Maxwell
Ghislaine Maxwell Attorney-Client Mark Cohen
Letter addressed to Cohen regarding United States v. Ghislaine Maxwell

Key Quotes (4)

"Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02771981 through SDNY_GM_02771983."
Source
EFTA00010180.pdf
Quote #1
"This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order."
Source
EFTA00010180.pdf
Quote #2
"Amazon records"
Source
EFTA00010180.pdf
Quote #3
"Although the Government believes that all of these materials are also located in the Florida FBI file and were previously produced to you from that file in the fall of 2020, out of an abundance of caution, the Government is producing these records to you..."
Source
EFTA00010180.pdf
Quote #4

Full Extracted Text

Complete text extracted from the document (2,506 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
November 11, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
[REDACTED]
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[REDACTED]
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
[REDACTED]
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_02771981 through SDNY_GM_02771983.
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:
EFTA00010180
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02771981 | SDNY_GM_02771983 | Amazon records |
Although the Government believes that all of these materials are also located in the Florida FBI file and were previously produced to you from that file in the fall of 2020, out of an abundance of caution, the Government is producing these records to you in the form in which they were stored in the files maintained by the U.S. Attorney’s Office for the Southern District of Florida. 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
by: s/
[REDACTED]
Assistant United States Attorneys
EFTA00010181

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