442-01.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 3
- Text status
- Searchable text available
- OCR confidence
- 0.9035800675932255
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 442-1 Filed 11/12/21 Page1lof3 EXHIBIT A DOJ-OGR-00006584
Case 1:20-cr-00330-PAE Document 442-1 Filed 11/12/21 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: We write to notify you that the Government may seek to introduce certain evidence at trial. In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition to the defendant’s conduct with Jeffrey Epstein, the defendant took steps to please other influential roviding them with access to women she selected for them. We are producing these proposed exhibits today, marked with the following exhibit numbers: GX 401 through 404, GX 409 through 410, and GX 413. In addition, please be advised that the Government may call as a witness at trial. Today, we are producing Jencks Act materials relating to , who was employed by Jeffrey Epstein —_— The Government anticipates ‘ha will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that a will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls. DOJ-OGR-00006585
Case 1:20-cr-00330-PAE Document 442-1 Filed 11/12/21 Page3of3 Page 2 This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant’s intent, preparation, plan, knowledge, identity, and/or absence of …
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