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EFTA00028257.pdf

78 KB

Extraction Summary

6
People
5
Organizations
4
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / discovery letter
File Size: 78 KB
Summary

A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 9, 2021, regarding the production of discovery materials (Jencks Act and Giglio) for her trial. The letter explains that materials previously designated as 'confidential' are now marked with a specific reference to the Protective Order paragraphs to avoid confusion with classified document markings.

People (6)

Name Role Context
Damian Williams United States Attorney
Sender of the letter representing the US Government
Ghislaine Maxwell Defendant
Subject of the case United States v. Ghislaine Maxwell
Christian Everdell 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

Organizations (5)

Name Type Context
U.S. Department of Justice
Government agency prosecuting the case
United States Attorney Southern District of New York
Specific office handling the prosecution
Cohen & Gresser LLP
Defense law firm
Haddon, Morgan and Foreman, P.C.
Defense law firm
Law Offices of Bobbi C. Sternheim
Defense law firm

Timeline (1 events)

2021-11-09
Production of Jencks Act and Giglio material regarding witnesses for the Ghislaine Maxwell trial.
New York, NY
US Government Defense Counsel

Locations (4)

Location Context
Address of the US Attorney's Office
Address of Cohen & Gresser LLP
Address of Haddon, Morgan and Foreman, P.C.
Address of Law Offices of Bobbi C. Sternheim

Relationships (2)

Damian Williams Prosecutor vs Defendant Ghislaine Maxwell
Letter heading 'United States v. Ghislaine Maxwell' sent by US Attorney Damian Williams
Christian Everdell Defense Attorney Ghislaine Maxwell
Listed as counsel in 'United States v. Ghislaine Maxwell'

Key Quotes (3)

"Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial"
Source
EFTA00028257.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
EFTA00028257.pdf
Quote #2
"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."
Source
EFTA00028257.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (1,973 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.
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
Bobbi Sternheim, Esq.
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:
Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today’s production.
Please note that this letter, the enclosed index, and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. In particular, the materials are designated as “confidential” under the Protective Order. The index 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.
EFTA00028257
Page 2
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/ [REDACTED]
Assistant United States Attorneys
EFTA00028258

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