The Silvio J. Mollo Building
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061.pdf
This document is a formal letter filed on July 29, 2021, in the case of United States v. Tova Noel et al. Assistant US Attorney Jessica Lonergan informs Judge Analisa Torres that she is leaving the US Attorney's Office for other employment and requests to be removed as counsel of record. Judge Torres approves the request with a 'So Ordered' signature at the bottom of the page.
060.pdf
A formal notice filed on July 29, 2021, by Assistant United States Attorney Jessica Lonergan to Judge Analisa Torres in the case of United States v. Tova Noel et al. Lonergan informs the court that she is leaving the U.S. Attorney's Office for other employment and requests to be removed as counsel of record for the prosecution.
022.pdf
This document is a letter from the U.S. Attorney's Office (SDNY) to Judge Analisa Torres in the case of United States v. Noel and Thomas, dated January 28, 2020. The Government opposes the defendants' request for a six-month adjournment of the trial scheduled for April 20, 2020, arguing that the case focuses on a narrow 14-hour window (the night of Jeffrey Epstein's death) and that discovery has been provided promptly. The prosecutors state they would not object to a 'brief' adjournment but deem six months unnecessary.
013.pdf
This is a court filing dated December 16, 2019, from the US Attorney's Office for the Southern District of New York to Judge Analisa Torres regarding the case 'United States v. Noel and Thomas' (the case against the guards on duty during Jeffrey Epstein's death). The prosecutors are submitting a proposed protective order with the consent of the defense counsel. The letter is signed by Assistant US Attorneys Rebekah Donaleski, Nicolas Roos, and Jessica Lonergan on behalf of US Attorney Geoffrey S. Berman.
EFTA00037899.pdf
This document is a formal preservation letter dated December 12, 2018, from the U.S. Attorney's Office for the Southern District of New York. It directs an unnamed entity (likely a tech or email provider) to preserve all content, specifically including emails in Draft or Trash folders, associated with specific redacted accounts pursuant to 18 U.S.C. § 2703(f)(1). The letter emphasizes the need for secrecy due to an ongoing investigation and requests that the subscriber not be notified of the preservation order.
EFTA00032002.pdf
A letter dated June 10, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center. The letter provides a password (which is redacted in the document) for a disc containing discovery materials related to the case United States v. Ghislaine Maxwell (20 Cr. 330).
EFTA00031951.pdf
A letter dated December 3, 2020, from the U.S. Attorney's Office (SDNY) to the Legal Department at the Metropolitan Detention Center (MDC) in Brooklyn. The letter provides a password (which is redacted in the document) for a hard drive containing discovery materials related to the case United States v. Ghislaine Maxwell.
EFTA00031950.pdf
A letter dated December 3, 2020, from Acting U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. The letter encloses discovery materials pertinent to the case United States v. Ghislaine Maxwell (20 Cr. 330) and requests that inmate Ghislaine Maxwell (ID 02879-509) be allowed access to these materials. The names of the specific Assistant United States Attorneys signing the document are redacted.
EFTA00031113.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 24, 2021, detailing the production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials for individuals the government does not currently intend to call. The letter also clarifies protective order designations for the enclosed documents.
EFTA00031016.pdf
This document is a discovery letter dated May 3, 2021, from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team. It accompanies the production of photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) designated as confidential under a Protective Order.
EFTA00030094.pdf
A cover letter from the U.S. Attorney's Office (SDNY) to the Metropolitan Detention Center dated March 16, 2021. The letter encloses discovery materials for inmate Ghislaine Maxwell regarding case 20 Cr. 330 (AJN) and requests that she be granted access to these materials.
EFTA00029979.pdf
A cover letter dated November 18, 2020, from the U.S. Attorney's Office (SDNY) to the Metropolitan Detention Center in Brooklyn. The letter encloses discovery materials for inmate Ghislaine Maxwell (Register No. 02879-509) in relation to the case United States v. Ghislaine Maxwell, requesting that she be allowed access to the documents.
EFTA00029417.pdf
A letter dated August 12, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. The letter provides a password (which is redacted) for a hard drive containing discovery materials related to the case United States v. Ghislaine Maxwell.
EFTA00029416.pdf
A letter dated August 12, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. The letter encloses discovery materials relevant to the case United States v. Ghislaine Maxwell (20 Cr. 330) and requests that the inmate, Ghislaine Maxwell (02879-509), be allowed access to these materials.
EFTA00028785.pdf
This document is a letter from the U.S. Attorney for the Southern District of New York to Judge Richard Berman, arguing against Jeffrey Epstein's motion for pretrial release. The government details Epstein's extreme flight risk due to his vast wealth (over $500 million), international ties (Paris, Virgin Islands), and private aviation access. It also highlights his danger to the community and obstruction of justice history, citing recent wire transfers to potential witnesses and the discovery of lewd photographs of minors in his home. The government argues that his proposed bail package, including home confinement and private security, is inadequate.
EFTA00028579.pdf
This document is a letter dated May 21, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department of the Metropolitan Detention Center (MDC) in Brooklyn. It concerns the case 'United States v. Ghislaine Maxwell' and provides a password (which is redacted) for a disc containing discovery materials pertinent to the defendant. The document is signed by an Assistant US Attorney on behalf of Strauss, though the specific signatory's name is redacted.
EFTA00028578.pdf
This document is a letter dated May 21, 2021, from U.S. Attorney Audrey Strauss (SDNY) to the Legal Department at the Metropolitan Detention Center (MDC) in Brooklyn. The letter encloses discovery materials for inmate Ghislaine Maxwell (Register No. 02879-509) regarding the case United States v. Ghislaine Maxwell and requests that she be granted access to these materials.
EFTA00028265.pdf
A joint letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding the trial of Ghislaine Maxwell. The letter outlines the Government and Defense positions on protecting witness identities, including the use of pseudonyms (nomenclature), voir dire procedures, jury instructions, and the handling of sealed exhibits to prevent public disclosure of victim identities. The document contains significant redactions regarding the actual names and pseudonyms of the witnesses.
EFTA00027732.pdf
This document is a discovery letter from the U.S. Department of Justice to the attorney for Tova Noel, a correctional officer charged in connection with Jeffrey Epstein's death. It lists extensive materials being provided to the defense, including MCC surveillance footage, computer analysis, phone records, and internal logs from the dates surrounding Epstein's death (August 9-10, 2019). The letter also discloses Brady material consisting of statements from inmates regarding the timeline of officer rounds on the night Epstein died, contradicting or clarifying the official timeline.
EFTA00027704.pdf
A letter from U.S. Attorney Damian Williams to Judge Alison J. Nathan dated October 18, 2021, regarding the case United States v. Ghislaine Maxwell. The Government requests permission to file motions *in limine* with redactions designed to protect the privacy of victims and third parties, specifically requesting the sealing of 'Section X' until the conclusion of the trial. The specific Assistant US Attorney signing the document has their name redacted.
EFTA00025165.pdf
A letter dated October 29, 2021, from U.S. Attorney Damian Williams (SDNY) to Ghislaine Maxwell at MDC Brooklyn. The letter transmits a password for a disc containing discovery materials and government exhibits related to the case United States v. Ghislaine Maxwell (20 Cr. 330). The document contains several redactions, including the password and specific identifiers.
EFTA00025035.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team regarding the production of Jencks Act and Giglio materials for potential trial witnesses. The letter clarifies a stamping error in a previous production (October 11, 2021) involving records 3501.507-516 and explains new labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00024225.pdf
A letter dated October 26, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell at MDC Brooklyn. The letter provides a password (which is redacted in the document) for a disc containing witness materials and discovery related to her case, United States v. Ghislaine Maxwell.
EFTA00024224.pdf
A cover letter dated October 26, 2021, from U.S. Attorney Damian Williams (SDNY) to MDC Brooklyn regarding the case United States v. Ghislaine Maxwell. The letter encloses witness materials and discovery documents for inmate Ghislaine Maxwell (Reg. No. 02879-509) and requests that she be allowed access to them.
EFTA00024223.pdf
A letter dated October 26, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell at MDC Brooklyn. The letter provides the password (which is redacted) for a disc containing witness materials and discovery relevant to her case, United States v. Ghislaine Maxwell.
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