384-01.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 3
Text status: Searchable text available
OCR confidence: 0.9108395265696493

Extracted text

Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page1lof3 EXHIBIT 1 DOJ-OGR-00005607

Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page2of3 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 October 11, 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 FI. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Pursuant to Judge Nathan’s Order of September 3, 2021 (Dkt. No. 335), the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E): e Jeffrey Epstein The Government has produced all co-conspirator statements which it intends to offer at trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government’s production today or in its previous productions. To the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material. DOJ-OGR-00005608

Case 1:20-cr-00330-PAE Document 384-1 Filed 10/29/21 Page3of3 Page 2 Please be advised that the above list is limited to the individuals the Government may refer to as co-conspirators at trial. While the Government makes no representations as to whether it views other individuals as potential or actual co-conspirators of the defendant, it does not intend to refer to any other individuals as co-conspirators at trial. The above list is also not intended to reflect a complete list of individuals who may be referenced at trial. That information is contained …

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