EFTA00010017.pdf
98.7 KB
Extraction Summary
7
People
7
Organizations
2
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence (discovery letter)
File Size:
98.7 KB
Summary
A discovery letter dated November 9, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. The letter accompanies the production of 'Business Records from SDFL Files' (Bates SDNY_GM_02767074 - 02771980), which the government notes are likely duplicative of materials previously produced from Florida FBI files in 2020. The letter also clarifies confidentiality designations under the Protective Order.
People (7)
| Name | Role | Context |
|---|---|---|
| Damian Williams | United States Attorney |
Sender of the letter representing the U.S. Department of Justice
|
| Ghislaine Maxwell | Defendant |
Subject of the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
|
| Christian Everdell | Defense Counsel |
Recipient, lawyer at Cohen & Gresser LLP
|
| Mark Cohen | Defense Counsel |
Recipient, lawyer at Cohen & Gresser LLP
|
| Laura Menninger | Defense Counsel |
Recipient, lawyer at Haddon, Morgan and Foreman, P.C.
|
| Jeffrey Pagliuca | Defense Counsel |
Recipient, lawyer at Haddon, Morgan and Foreman, P.C.
|
| Bobbi Sternheim | Defense Counsel |
Recipient, lawyer at Law Offices of Bobbi C. Sternheim
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Government agency sending the letter
|
|
| United States Attorney's Office, Southern District of New York |
Specific office handling the prosecution
|
|
| Cohen & Gresser LLP |
Defense law firm
|
|
| Haddon, Morgan and Foreman, P.C. |
Defense law firm
|
|
| Law Offices of Bobbi C. Sternheim |
Defense law firm
|
|
| Southern District of Florida (SDFL) |
Origin of the business records produced
|
|
| FBI |
Mentioned regarding Florida FBI files previously produced
|
Timeline (3 events)
2020-09-01
Fall of 2020: Previous production of Florida FBI file materials.
Florida
Government
Defense
2021-11-09
Production of discovery materials (Business Records from SDFL Files) by the Government to the Defense.
New York, NY
U.S. Government
Defense Counsel
Locations (2)
| Location | Context |
|---|---|
|
Location of the U.S. Attorney's Office SDNY
|
|
|
Location of original files (SDFL) and FBI file
|
Relationships (2)
Letter header 'United States v. Ghislaine Maxwell'
Addressed as counsel in Re: United States v. Ghislaine Maxwell
Key Quotes (3)
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."Source
EFTA00010017.pdf
Quote #1
"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
EFTA00010017.pdf
Quote #2
"Although the Government believes that all of these materials are also located in the Florida FBI file and were previously produced to 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."Source
EFTA00010017.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,636 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 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
[Redacted]
Mark Cohen, Esq.
Cohen & Gresser LLP
[Redacted]
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[Redacted]
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[Redacted]
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
[Redacted]
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_02767074 through SDNY_GM_02771980.
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:
EFTA00010017
Page 2
Bates Start: SDNY_GM_02767074
Bates End: SDNY_GM_02771980
Summary Description: Business Records from SDFL Files¹
Confidential Designation: Confidential
Bates End: SDNY_GM_02771980
Summary Description: Business Records from SDFL Files¹
Confidential Designation: Confidential
Although the Government believes that all of these materials are also located in the Florida FBI file and were previously produced to 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,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
[Redacted Signature Block]
________________________
¹ These materials appear to be largely duplicative of materials previously produced to you in discovery.
¹ These materials appear to be largely duplicative of materials previously produced to you in discovery.
EFTA00010018
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document