EFTA00010133.pdf

89.2 KB

Extraction Summary

7
People
5
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / discovery letter
File Size: 89.2 KB
Summary

This document is a discovery letter dated November 9, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It details the production of 'SDFL Files' (likely Southern District of Florida files) with Bates numbers SDNY_GM_02767074 through SDNY_GM_02771980. The letter notes these materials are confidential under a protective order and appear to be duplicative of previous discovery.

People (7)

Name Role Context
Damian Williams United States Attorney
Sender of the letter representing the U.S. Government (SDNY).
Ghislaine Maxwell Defendant
Subject of the case: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).
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.

Timeline (1 events)

2021-11-09
Production of discovery materials labeled 'SDFL Files' to the defense team.
New York, NY
US Attorney's Office SDNY Defense Counsel for Ghislaine Maxwell

Relationships (2)

Damian Williams Prosecutor/Defendant Ghislaine Maxwell
Letter regarding United States v. Ghislaine Maxwell sent by US Attorney Williams.
Christian Everdell Counsel/Client Ghislaine Maxwell
Addressed as counsel in US v. 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
EFTA00010133.pdf
Quote #1
"The materials being produced today are marked with the following label: 'SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17.'"
Source
EFTA00010133.pdf
Quote #2
"These materials appear to be largely duplicative of materials previously produced to you in discovery."
Source
EFTA00010133.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,219 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 9, 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_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:
EFTA00010133
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
SDNY_GM_02767074 | SDNY_GM_02771980 | SDFL Files¹ | 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
[REDACTED]
___________________
¹ These materials appear to be largely duplicative of materials previously produced to you in discovery.
EFTA00010134

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