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22-1426_Documents.pdf
This document consists of a Docketing Notice from the Second Circuit Court of Appeals dated July 8, 2022, for the appeal of Ghislaine Maxwell (Case 22-1426), and a Notice of Appeal and Criminal Docket from the Southern District of New York (Case 1:20-cr-00330-AJN) filed July 7, 2022. It details Maxwell's conviction and sentencing, including multi-year imprisonment terms and a $750,000 fine for charges related to conspiracy to entice minors for illegal sex acts, transport minors for sexual activity, and sex trafficking, with some counts dismissed or deemed multiplicitous.
EFTA00032021.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated September 15, 2021. It serves as notice that the government intends to call FBI Computer Forensic Examiner Stephen [Redacted] as an expert witness to testify regarding the extraction of data from seized electronic devices. The letter also reiterates previous government requests from 2020 and early 2021 for reciprocal discovery and expert witness notices from the defense.
EFTA00031952.pdf
This document is an email chain from December 4, 2020, involving defense attorney Christian Everdell of Cohen & Gresser LLP and prosecutors from the US Attorney's Office (USANYS). The correspondence concerns a draft letter regarding a briefing schedule to be sent to Judge Nathan in the Ghislaine Maxwell case. The top email indicates approval of the draft ('Fine with me') from one of the recipients.
EFTA00031440.pdf
This document is a discovery production letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team, dated April 14, 2021. It details the production of a single photograph (Bates number SDNY_GM_02753398) designated as 'Confidential' under a Protective Order. The letter is signed by U.S. Attorney Audrey Strauss, with the specific Assistant U.S. Attorneys' signatures redacted.
EFTA00031437.pdf
A discovery letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team dated April 14, 2021. The letter documents the production of a single item, a photograph (Bates SDNY_GM_02753398), which is designated as confidential under a July 2020 Protective Order. The specific names of the Assistant U.S. Attorneys signing the document are redacted.
EFTA00030992.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 21, 2020. It outlines the production of various evidentiary materials, including Boies Schiller documents, emails, search warrant photos, Jeffrey Epstein's deposition recordings (2010), travel records, and SORNA records. The letter explicitly notes that 'highly confidential' materials containing sexualized images are being provided only to counsel, not the defendant, and refuses to produce a separate FBI obstruction file regarding a redacted former employee of Epstein deemed irrelevant to the case.
EFTA00030941.pdf
This document is an email thread between defense attorney Christian Everdell (Cohen & Gresser LLP) and the US Attorney's Office for the Southern District of New York (USANYS). On December 28, 2020, Everdell requested a Bill of Particulars. On January 10, 2021, the USANYS responded with an attached letter regarding the request in the Ghislaine Maxwell case (indicated by 'GM' in the filename).
EFTA00028257.pdf
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.
EFTA00028103.pdf
A formal 'Touhy request' letter dated August 30, 2021, from Ghislaine Maxwell's attorney Christian Everdell to Assistant Attorney General Kenneth Polite. The letter requests the testimony of four redacted FBI/Task Force agents for Maxwell's upcoming trial. These agents were involved in two key investigations: the 2006-2008 Palm Beach FBI investigation into Jeffrey Epstein and the subsequent New York FBI investigation that led to the 2019/2020 indictments of Epstein and Maxwell.
EFTA00028045.pdf
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.
EFTA00025066.pdf
This document is a letter dated October 11, 2021, from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense team. It formally notifies the defense that the government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, specifically for the purpose of admitting evidence under the co-conspirator hearsay exception. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00024868.pdf
A discovery cover letter dated May 3, 2021, from U.S. Attorney Audrey Strauss's office to Ghislaine Maxwell's defense team. The letter accompanies the production of photographs stamped SDNY_GM_02753399 through SDNY_GM_02753431, noting that the materials and the letter itself are designated as confidential under a Protective Order.
EFTA00023329.pdf
Defense counsel Christian Everdell writes to Judge Alison Nathan opposing the government's request to delay the disclosure of evidence (photographs and documents) regarding alleged victims of Jeffrey Epstein. The defense argues these materials are exculpatory under Brady because they relate to post-1997 allegations where witnesses do not implicate Maxwell, thereby supporting her defense against perjury charges that she was unaware of Epstein's abuse. The letter also argues the government has failed to show 'good cause' under Rule 16 to delay this discovery.
EFTA00022514.pdf
This document is a letter motion filed by Ghislaine Maxwell's defense attorney, Christian Everdell, on April 30, 2021, requesting Judge Alison Nathan to order the Metropolitan Detention Center (MDC) to accept two hard drives containing discovery materials for Maxwell's review. The defense argues the current format of 2.2 million pages is difficult to navigate, and they have reorganized the files to be more user-friendly. Judge Nathan granted the order on May 3, 2021, with a stipulation allowing MDC counsel to submit objections by May 4, 2021.
EFTA00021941.pdf
This document is a formal letter from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team, dated October 11, 2021. It serves to notify the defense that the Government intends to refer to Jeffrey Epstein and other redacted individuals as co-conspirators during the trial, pursuant to a court order. The letter is marked as Exhibit 1 and designated as confidential under a protective order.
EFTA00021769.pdf
An email chain from July 2020 involving defense attorneys (Christian Everdell, Mark Cohen, et al.) discussing a 'Protective Order' for discovery, likely in the Ghislaine Maxwell case (implied by 'GM' in filenames). Everdell sends a revised draft to the Government following a call on July 20th. The top emailer (name redacted) forwards this message expressing confusion, noting they cannot see the difference between the attached documents or find the redline.
EFTA00021036.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 23, 2021. The letter details the production of Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials regarding individuals the government does not currently plan to call. It also clarifies confidentiality designations under a Protective Order.
EFTA00021034.pdf
A letter from U.S. Attorney Damian Williams to Ghislaine Maxwell's defense counsel dated November 23, 2021, accompanying a discovery production. The production includes JPMC records, phone records, and other documents designated as confidential under a protective order. The letter clarifies labeling protocols for confidential materials to distinguish them from classified documents.
EFTA00020815.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated October 13, 2021. It accompanies the production of spreadsheets previously reviewed by the defense at an FBI office in Denver. The letter notes that the original spreadsheets contained embedded hyperlinks to images of 'child exploitation materials,' necessitating the creation of a sanitized version for production.
EFTA00020105.pdf
A formal letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated October 11, 2021. The letter discloses that the Government intends to refer to Jeffrey Epstein and two other redacted individuals (one with a former alias) as 'co-conspirators' during the upcoming trial. The document is marked confidential under a protective order.
EFTA00019420.pdf
A discovery letter dated December 16, 2020, from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team. The letter documents the production of materials designated as confidential, specifically referencing a 'UBS Subpoena Return' dated December 15, 2020. The document indicates ongoing discovery obligations and mentions that physical items are in FBI custody.
EFTA00019404.pdf
An email dated November 22, 2021, from the law firm Cohen & Gresser LLP (representing Ghislaine Maxwell) to Judge Alison J. Nathan's chambers. The email submits a letter regarding proposed limiting instructions related to a Court Opinion and Order from November 19, 2021, noting that the submission is temporarily under seal.
EFTA00014650.pdf
A letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team dated November 20, 2021, accompanying a production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as statements from individuals the government does not currently plan to call. The letter also clarifies labeling protocols for confidential documents under the Protective Order to avoid confusion with classified material.
EFTA00011418.pdf
This document is a discovery request letter from Ghislaine Maxwell's defense counsel, Cohen & Gresser LLP, to the US Attorney's Office for the Southern District of New York, dated October 13, 2020. The defense requests a wide range of materials including exculpatory Brady evidence, information on Minor Victims 1-3, communications regarding Jeffrey Epstein's 2007 Non-Prosecution Agreement, and records of coordination between the government and civil attorneys representing Epstein's accusers. The letter also requests specific FBI files, unredacted reports, and evidence related to the credibility and potential financial motives of government witnesses.
DOJ-OGR-00008435.jpg
This document is the signature page (page 5 of 5) of a legal filing dated December 15, 2021, addressed to Judge Alison J. Nathan in the case regarding Ghislaine Maxwell. It lists the contact information and signatures of Maxwell's defense attorneys: Jeffrey S. Pagliuca, Laura A. Menninger, Christian R. Everdell, and Bobbi C. Sternheim.
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