EFTA00021034.pdf

93.7 KB

Extraction Summary

7
People
6
Organizations
4
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence (discovery letter)
File Size: 93.7 KB
Summary

A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 23, 2021, accompanying a discovery production. The production includes JPMC records, phone records, and other documents designated as confidential under a protective order. The letter clarifies labeling protocols for confidential materials to distinguish them from classified documents.

People (7)

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, 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 (6)

Name Type Context
U.S. Department of Justice
Government agency issuing the document
United States Attorney's Office Southern District of New York
Specific office prosecuting the case
Cohen & Gresser LLP
Law firm representing the defendant
Haddon, Morgan and Foreman, P.C.
Law firm representing the defendant
Law Offices of Bobbi C. Sternheim
Law firm representing the defendant
JPMC
JPMorgan Chase, mentioned in the index regarding produced records

Timeline (1 events)

2021-11-23
Production of discovery materials by the US Government to Ghislaine Maxwell's defense team.
New York, NY
US Attorney's Office SDNY Ghislaine Maxwell Defense Team

Locations (4)

Location Context
Address of U.S. Attorney's Office
Address of Cohen & Gresser LLP
Address of Haddon, Morgan and Foreman, P.C.
Address of Law Offices of Bobbi C. Sternheim

Relationships (2)

Damian Williams Prosecutor/Defendant Ghislaine Maxwell
Williams is the US Attorney in the case United States v. Ghislaine Maxwell.
Christian Everdell Attorney/Client Ghislaine Maxwell
Addressed as counsel in Re: United States v. Ghislaine Maxwell.

Key Quotes (3)

"Today we are producing the materials listed in the below index."
Source
EFTA00021034.pdf
Quote #1
"This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order."
Source
EFTA00021034.pdf
Quote #2
"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
EFTA00021034.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,382 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 23, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
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
Bobbi Sternheim, Esq.
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 materials are stamped with control numbers SDNY_GM_02775032 through SDNY_GM_02775072.
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:
EFTA00021034
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02775032 | SDNY_GM_02775065 | JPMC records | Confidential
SDNY_GM_02775066 | SDNY_GM_02775069 | Phone records | Confidential
SDNY_GM_02775070 | SDNY_GM_02775072 | Other records | 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
by: s/
[REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
EFTA00021035

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