EFTA00020105.pdf
85.1 KB
Extraction Summary
10
People
5
Organizations
4
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / government disclosure letter
File Size:
85.1 KB
Summary
A formal letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 11, 2021. The letter discloses that the Government intends to refer to Jeffrey Epstein and two other redacted individuals (one with a former alias) as 'co-conspirators' during the upcoming trial. The document is marked confidential under a protective order.
People (10)
| Name | Role | Context |
|---|---|---|
| Damian Williams | United States Attorney |
Sender (Signatory)
|
| 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
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell)
|
| Judge Nathan | Judge |
Issued Order of September 3, 2021
|
| Jeffrey Epstein | Co-conspirator |
Named explicitly as a co-conspirator the government will refer to at trial
|
| Redacted Individual 1 | Co-conspirator |
Name redacted in bullet point list
|
| Redacted Individual 2 | Co-conspirator |
Name redacted, described as 'formerly known as [Redacted]'
|
Timeline (2 events)
Relationships (3)
Government explicitly lists Jeffrey Epstein as a co-conspirator of the defendant.
Government lists redacted individual as a co-conspirator.
Government lists redacted individual (formerly known as...) as a co-conspirator.
Key Quotes (4)
"the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant"Source
EFTA00020105.pdf
Quote #1
"• Jeffrey Epstein"Source
EFTA00020105.pdf
Quote #2
"• [Redacted], formerly known as [Redacted]"Source
EFTA00020105.pdf
Quote #3
"This letter is itself designated as 'confidential' under the Protective Order."Source
EFTA00020105.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (2,276 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
October 11, 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:
Pursuant to Judge Nathan’s Order of September 3, 2021 (Dkt. No. 335), the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E):
• Jeffrey Epstein
• [REDACTED]
• [REDACTED], formerly known as [REDACTED]
• [REDACTED]
• [REDACTED], formerly known as [REDACTED]
The Government has produced all co-conspirator statements which it intends to offer at trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government’s production today or in its previous productions. To the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material.
EFTA00020105
Page 2
Please be advised that the above list is limited to the individuals the Government may refer to as co-conspirators at trial. While the Government makes no representations as to whether it views other individuals as potential or actual co-conspirators of the defendant, it does not intend to refer to any other individuals as co-conspirators at trial. The above list is also not intended to reflect a complete list of individuals who may be referenced at trial. That information is contained in the Government’s Jencks Act production(s).
Please note that this letter and the information contained herein is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as “confidential” under the Protective Order.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
United States Attorney
By: s/ [REDACTED]
[REDACTED]
[REDACTED]
Assistant United States Attorneys
Southern District of New York
[REDACTED]
[REDACTED]
Assistant United States Attorneys
Southern District of New York
EFTA00020106
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