EFTA00030943.pdf

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pdf

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data-set-8

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U.S. Department of Justice 
United States Attorney 
Southern District of New York 
By Electronic Mail 
Christian Everdell, Esq. 
Mark Cohen, Esq. 
ohen & Gresser LLP 
Laura Menninger, Esq. 
Jeffrey Pagliuca, Esq. 
Haddon Mor an and Foreman, P.C. 
Dear Counsel: 
The Silvio J. Mono Building 
One Saint Andrew's Plaza 
New York. New York 10007 
January 10, 2021 
Bobbi Sternheim, Esq. 
Law Offices of Bobbi C. Sternheim 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
We write in response to your letter of December 28, 2020, in which you request a bill of 
particulars in the above-captioned matter. As set forth herein, the Government does not intend to 
provide further particulars because under the well-established law of this Circuit it has no 
obligation to do so. To the contrary, and as you are aware, the Government outlined its charges 
against your client in a detailed speaking superseding indictment (the "Indictment") and has since 
provided considerable additional information through the production of to date of over 2.7 million 
items of discovery, all in electronic form and accompanied by an index. Accordingly, the 
Government has more than provided the defendant with adequate notice of the charges against her, 
and no further particulars are required. 
"A bill of particulars is required only where the charges of the indictment are so general 
that they do not advise the defendant of the specific acts of which he is accused." United States v. 
Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., 
United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 
2014) (same); United States v. Mandell, 710 F. Supp. 2d 368, 384 (S.D.N.Y. 2010) (same). 
"Acquisition of evidentiary details is not the function of the bill of particulars." United States v. 
Torres, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 
628 F.3d 36, 41 (2d Cir. 2010) (quotation…

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