EFTA00014650.pdf
99.7 KB
Extraction Summary
6
People
4
Organizations
4
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (discovery letter)
File Size:
99.7 KB
Summary
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 20, 2021, accompanying a production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as statements from individuals the government does not currently plan to call. The letter also clarifies labeling protocols for confidential documents under the Protective Order to avoid confusion with classified material.
People (6)
| Name | Role | Context |
|---|---|---|
| Damian Williams | United States Attorney |
Sender of the letter (SDNY)
|
| Ghislaine Maxwell | Defendant |
Subject of the case: United States v. Ghislaine Maxwell
|
| Christian Everdell | 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 (4)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Sender, US Attorney's Office SDNY
|
|
| Cohen & Gresser LLP |
Defense counsel firm
|
|
| Haddon, Morgan and Foreman, P.C. |
Defense counsel firm
|
|
| Law Offices of Bobbi C. Sternheim |
Defense counsel firm
|
Timeline (1 events)
2021-11-20
Production of Jencks Act and Giglio materials by the Government to the Defense.
New York, NY
US Government
Defense Counsel
Locations (4)
| Location | Context |
|---|---|
|
SDNY Address
|
|
|
Address for Cohen & Gresser LLP
|
|
|
Address for Haddon, Morgan and Foreman, P.C.
|
|
|
Address for Bobbi Sternheim
|
Relationships (2)
Letter addressed to Everdell regarding U.S. v. Maxwell
Letter addressed to Menninger regarding U.S. v. Maxwell
Key Quotes (4)
"Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial"Source
EFTA00014650.pdf
Quote #1
"The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial"Source
EFTA00014650.pdf
Quote #2
"In particular, the materials are designated as 'confidential' under the Protective Order."Source
EFTA00014650.pdf
Quote #3
"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
EFTA00014650.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,899 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
November 20, 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:
Today the Government is producing additional materials, including Jencks Act and
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today’s production.
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced
case. Enclosed please find an index detailing the materials included in today’s production.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00014650
Page 2
Please note that this letter, the enclosed index, and the enclosed materials are governed
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as “confidential” under the Protective Order. The index 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.
by the July 31, 2020 Protective Order in this case. In particular, the materials are designated
as “confidential” under the Protective Order. The index 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.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
by: s/ [REDACTED]
Assistant United States Attorneys
Assistant United States Attorneys
EFTA00014651
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document