EFTA00024987.pdf

90.2 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / discovery production letter
File Size: 90.2 KB
Summary

This document is a discovery production letter dated November 24, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It details the production of confidential records related to JPMC (JPMorgan Chase) and Lockheed Martin, governed by a Protective Order. The letter explains the specific confidentiality markings applied to the produced materials.

People (7)

Name Role Context
Damian Williams United States Attorney
Sender of the letter representing the U.S. Department of Justice.
Christian Everdell Defense Counsel
Recipient, attorney at Cohen & Gresser LLP.
Mark Cohen Defense Counsel
Recipient, attorney at Cohen & Gresser LLP.
Laura Menninger Defense Counsel
Recipient, attorney at Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca Defense Counsel
Recipient, attorney at Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim Defense Counsel
Recipient, attorney at Law Offices of Bobbi C. Sternheim.
Ghislaine Maxwell Defendant
Subject of the legal case (United States v. Ghislaine Maxwell).

Organizations (7)

Name Type Context
U.S. Department of Justice
Sender organization.
Southern District of New York
Office location of the U.S. Attorney.
Cohen & Gresser LLP
Firm representing the defendant.
Haddon, Morgan and Foreman, P.C.
Firm representing the defendant.
Law Offices of Bobbi C. Sternheim
Firm representing the defendant.
JPMC
Subject of produced records (JPMorgan Chase).
Lockheed Martin
Subject of produced records.

Timeline (1 events)

2021-11-24
Production of discovery materials by the Government to the Defense.
New York, NY
U.S. Attorney's Office SDNY Defense Counsel

Locations (2)

Location Context
Location of U.S. Attorney's office and recipient law firms.
Location of Haddon, Morgan and Foreman, P.C.

Relationships (1)

Damian Williams Adversarial (Prosecutor vs Defendant) Ghislaine Maxwell
Letter regarding United States v. Ghislaine Maxwell sent by U.S. Attorney.

Key Quotes (3)

"Today we are producing the materials listed in the below index."
Source
EFTA00024987.pdf
Quote #1
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."
Source
EFTA00024987.pdf
Quote #2
"The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware."
Source
EFTA00024987.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,269 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 24, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
[REDACTED]
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[REDACTED]
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
[REDACTED]
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_02775073 through SDNY_GM_02775777.
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:
EFTA00024987
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02775073 | SDNY_GM_02775087 | JPMC records | Confidential
SDNY_GM_02775088 | SDNY_GM_02775777 | Lockheed Martin 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]
Assistant United States Attorneys
EFTA00024988

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