EFTA00028045.pdf
129 KB
Extraction Summary
7
People
16
Organizations
4
Locations
1
Events
3
Relationships
6
Quotes
Document Information
Type:
Legal correspondence (discovery production letter)
File Size:
129 KB
Summary
This document is a discovery production letter dated October 1, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. It details the transfer of financial records from Deutsche Bank, JPMorgan Chase, Citibank, UBS, and American Express, many of which are designated as confidential. The letter specifically links Ghislaine Maxwell to various entities including the Terramar Project, Max Foundation, and Angara Trust via UBS records, and notes shared American Express records between Maxwell and Jeffrey Epstein.
People (7)
| Name | Role | Context |
|---|---|---|
| Audrey Strauss | Acting United States Attorney |
Sender of the letter representing the Government
|
| 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.
|
| Ghislaine Maxwell | Defendant |
Subject of the case and the financial records produced
|
| Jeffrey Epstein | Associate |
Mentioned in relation to American Express records shared with Ghislaine Maxwell
|
Organizations (16)
Timeline (1 events)
2020-10-01
Production of discovery materials (financial records) to the defense.
New York, NY
U.S. Department of Justice
Defense Counsel
Relationships (3)
Document lists 'American Express records for Jeffrey Epstein and Ghislaine Maxwell' (Bates SDNY_GM_00325762 - SDNY_GM_00328069)
UBS records listed covering both entities.
UBS records listed covering both entities.
Key Quotes (6)
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."Source
EFTA00028045.pdf
Quote #1
"Deutsche Bank records"Source
EFTA00028045.pdf
Quote #2
"JPMorgan Chase records"Source
EFTA00028045.pdf
Quote #3
"Citibank records for Ghislaine Maxwell"Source
EFTA00028045.pdf
Quote #4
"UBS records for Angara Trust, Montepelier Trust, Terramar Project, Inc., Max Foundation, Ghislaine Maxwell, Ghislaine Maxwell IRA, & Ellmax, LLC"Source
EFTA00028045.pdf
Quote #5
"American Express records for Jeffrey Epstein and Ghislaine Maxwell"Source
EFTA00028045.pdf
Quote #6
Full Extracted Text
Complete text extracted from the document (3,448 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 1, 2020
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
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_000174967 through SDNY_GM_ 00328863. The materials are available for pickup at the U.S. Attorney's Office in Manhattan.
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. An index of the materials contained in this production is below:
Bates Start Bates End Summary Description Confidential Designation
SDNY_GM_00174967 SDNY_GM_00270985 Deutsche Bank records Confidential
SDNY_GM_00270986; SDNY_GM_00323934;
SDNY_GM_00328070 SDNY_GM_00328863 JPMorgan Chase records Confidential
SDNY_GM_00323935 SDNY_GM 00324015 GM Documents
SDNY_GM_00174967 SDNY_GM_00270985 Deutsche Bank records Confidential
SDNY_GM_00270986; SDNY_GM_00323934;
SDNY_GM_00328070 SDNY_GM_00328863 JPMorgan Chase records Confidential
SDNY_GM_00323935 SDNY_GM 00324015 GM Documents
1 Files in PDF format designated as "confidential" under the protective order have been stamped "confidential." However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. Such files include in their electronic names the word "Confidential."
06.20.2018
EFTA00028045
EFTA00028045
Page 2
SDNY GM 00324016 SDNY GM 00324036 Citibank records for Ghislaine Maxwell
SDNY_GM_00324037 SDNY_GM_00325754 UBS records for Angara Trust, Montepelier Trust, Terramar Project, Inc., Max Foundation, Ghislaine Maxwell, Ghislaine Maxwell IRA, & Ellmax, LLC
SDNY GM 00325755 SDNY GM 00325761 LSJ Scene2Go
SDNY_GM_00325762 SDNY_GM_00328069 American Express records for Jeffrey Epstein and Ghislaine Maxwell Confidential
SDNY GM 00324016 SDNY GM 00324036 Citibank records for Ghislaine Maxwell
SDNY_GM_00324037 SDNY_GM_00325754 UBS records for Angara Trust, Montepelier Trust, Terramar Project, Inc., Max Foundation, Ghislaine Maxwell, Ghislaine Maxwell IRA, & Ellmax, LLC
SDNY GM 00325755 SDNY GM 00325761 LSJ Scene2Go
SDNY_GM_00325762 SDNY_GM_00328069 American Express records for Jeffrey Epstein and Ghislaine Maxwell Confidential
The Government is also reproducing to the defendant the files specified in Defense's September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files, the Government offers the following instructions:
1. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and selecting "Edit with Notepad" or a similar text-viewing program.
2. Any video file can be opened with VLC, which has been included.
3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional purpose besides assisting in the operation of other (i.e. video) files.
4. Any previously flagged files that are not noted here have been converted to PDFs and/or had their file paths shortened to enable viewing.
2. Any video file can be opened with VLC, which has been included.
3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional purpose besides assisting in the operation of other (i.e. video) files.
4. Any previously flagged files that are not noted here have been converted to PDFs and/or had their file paths shortened to enable viewing.
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 or if you wish to arrange a time to review physical items in the FBI's custody.
Very truly yours,
AUDREY STRAUSS
Acting United States Attorney
Acting United States Attorney
by:
[REDACTED SIGNATURE]
Assistant United States Attorneys
[REDACTED SIGNATURE]
Assistant United States Attorneys
06.20.2018
EFTA00028046
EFTA00028046
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