EFTA00023360.pdf
97.9 KB
Extraction Summary
7
People
4
Organizations
4
Locations
1
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal correspondence / discovery letter
File Size:
97.9 KB
Summary
This document is a letter dated November 20, 2021, from the U.S. Department of Justice to Ghislaine Maxwell's defense team regarding the production of discovery materials. The government provided Jencks Act and Giglio materials for potential trial witnesses, as well as witness statements for individuals they did not currently intend to call to testify. The letter also clarifies confidentiality designations under a Protective Order.
People (7)
| Name | Role | Context |
|---|---|---|
| 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
|
| United States Attorney | Sender |
Signatory (Name Redacted)
|
| Assistant United States Attorneys | Sender |
Signatory (Names Redacted)
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice |
Sender, US Attorney's Office SDNY
|
|
| Cohen & Gresser LLP |
Defense counsel firm
|
|
| Haddon, Morgan and Foreman, P.C. |
Defense counsel firm
|
|
| Law Offices of Bobbi C. Sternheim |
Defense counsel firm
|
Timeline (1 events)
2021-11-20
Production of additional discovery materials (Jencks Act, Giglio material, witness statements) by the Government to the Defense.
New York, NY
Government (DOJ)
Defense Counsel
Locations (4)
| Location | Context |
|---|---|
|
Jurisdiction
|
|
|
DOJ Office location
|
|
|
Location of DOJ and some defense counsel
|
|
|
Location of Haddon, Morgan and Foreman, P.C.
|
Relationships (3)
Letter addresses Everdell regarding U.S. v. Ghislaine Maxwell
Letter addresses Menninger regarding U.S. v. Ghislaine Maxwell
Letter addresses Sternheim regarding U.S. v. Ghislaine Maxwell
Key Quotes (5)
"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."Source
EFTA00023360.pdf
Quote #1
"The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial."Source
EFTA00023360.pdf
Quote #2
"These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial."Source
EFTA00023360.pdf
Quote #3
"This production should not be taken to indicate that the Government believes it has any obligation to provide all of these materials; rather, we make this production as a courtesy."Source
EFTA00023360.pdf
Quote #4
"In particular, the materials are designated as “confidential” under the Protective Order."Source
EFTA00023360.pdf
Quote #5
Full Extracted Text
Complete text extracted from the document (2,884 characters)
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
New York, New York 10007
November 20, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Cohen & Gresser LLP
[REDACTED]
New York, NY 10022
Cohen & Gresser LLP
[REDACTED]
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[REDACTED]
Denver, CO 80203
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
[REDACTED]
Denver, CO 80203
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
[REDACTED]
New York, NY 10007
Law Offices of Bobbi C. Sternheim
[REDACTED]
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.
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.
The Government is also producing today certain materials relating to individuals the
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Government does not currently intend to call as witnesses at trial in the above-referenced case.
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the
Government does not expect to call these individuals to testify at trial. Instead, these materials
contain, among other things, certain witness statements. Enclosed please find an index detailing
these materials. This production should not be taken to indicate that the Government believes it
has any obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
EFTA00023360
Page 2
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.
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.
Very truly yours,
[REDACTED]
United States Attorney
United States Attorney
by: s/
[REDACTED]
Assistant United States Attorneys
[REDACTED]
Assistant United States Attorneys
EFTA00023361
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