EFTA00021685.pdf
82.4 KB
Extraction Summary
9
People
5
Organizations
4
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal correspondence / government disclosure letter
File Size:
82.4 KB
Summary
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated October 12, 2021. It serves as notice that the Government intends to introduce evidence showing Maxwell provided other men with access to women, in addition to her conduct with Epstein. The letter also discloses a redacted witness who worked for Epstein in 2005-2006 and will testify about scheduling sexualized massages with underage girls.
People (9)
| Name | Role | Context |
|---|---|---|
| Audrey Strauss | United States Attorney |
Sender of the letter representing the Government
|
| Ghislaine Maxwell | Defendant |
Subject of the case (United States v. Ghislaine Maxwell)
|
| Jeffrey Epstein | Associate |
Mentioned in relation to the defendant's conduct and employment of the witness
|
| Christian Everdell | Defense Counsel |
Recipient, Cohen & Gresser LLP
|
| Mark Cohen | 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
|
| [Redacted Witness] | Witness / Former Employee |
Employed by Epstein approx 2005-2006; anticipated to testify about scheduling sexualized massages
|
Timeline (2 events)
2005-2006
Approximate period of employment for the redacted witness by Jeffrey Epstein.
Unspecified
Jeffrey Epstein
Ms. [Redacted]
2021-10-12
Government production of Jencks Act materials relating to Ms. [Redacted] and proposed exhibits.
New York, NY
US Attorney's Office
Defense Counsel
Locations (4)
| Location | Context |
|---|---|
Relationships (3)
Letter mentions 'defendant's conduct with Jeffrey Epstein'
Witness was 'employed by Jeffrey Epstein from approximately 2005-2006'
Defendant 'took steps to provide other men with access to women'
Key Quotes (3)
"the defendant took steps to provide other men with access to women"Source
EFTA00021685.pdf
Quote #1
"Ms. [Redacted] will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls"Source
EFTA00021685.pdf
Quote #2
"We are producing these proposed exhibits today, marked with the following exhibit numbers: [list]"Source
EFTA00021685.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,170 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 12, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Mark Cohen, Esq.
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:
We write to notify you that the Government may seek to introduce certain evidence at trial.
In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition
to the defendant's conduct with Jeffrey Epstein, the defendant took steps to provide other men
with access to women. We are producing these proposed exhibits today, marked with the
following exhibit numbers: [list].
In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition
to the defendant's conduct with Jeffrey Epstein, the defendant took steps to provide other men
with access to women. We are producing these proposed exhibits today, marked with the
following exhibit numbers: [list].
In addition, please be advised that the Government may call [REDACTED] as a witness
at trial. Today, we are producing Jencks Act materials relating to Ms. [REDACTED], who was employed
by Jeffrey Epstein from approximately 2005-2006. The Government anticipates that Ms. [REDACTED]
will testify about, among other things, certain documentary evidence relating to the charged
crimes. The Government further anticipates that Ms. [REDACTED] will testify about her role in
scheduling sexualized massages for Jeffrey Epstein with underage girls.
at trial. Today, we are producing Jencks Act materials relating to Ms. [REDACTED], who was employed
by Jeffrey Epstein from approximately 2005-2006. The Government anticipates that Ms. [REDACTED]
will testify about, among other things, certain documentary evidence relating to the charged
crimes. The Government further anticipates that Ms. [REDACTED] will testify about her role in
scheduling sexualized massages for Jeffrey Epstein with underage girls.
This evidence is admissible as direct evidence of the crimes charged and, in the alternative,
pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity,
and/or absence of mistake of accident with respect to the charges in the above-referenced case.
pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity,
and/or absence of mistake of accident with respect to the charges in the above-referenced case.
EFTA00021685
Page 2
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.
2020 Protective Order in this case. This letter is itself designated as "confidential" under the
Protective Order.
Very truly yours,
AUDREY STRAUSS
United States Attorney
United States Attorney
by: /s
[REDACTED SIGNATURE BLOCK]
[REDACTED SIGNATURE BLOCK]
EFTA00021686
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