EFTA00010133.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of Justice
United States Attorney
Southern District of New York
The Si!lo J. Mollo Building
One Saint Andrew's Plaza
New York New York 10007
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Bobbi Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02767074 through SDNY_GM_02771980.
Please note that both this letter and the enclosed materials are governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records designated as "confidential" under the Protective
Order. The Department of Justice directed this office to cease the dissemination of materials
marked with the word "confidential" in order to avoid potential confusion with markings reserved
for classified documents. Accordingly, in order to note the appropriate designation of this
production under the operative Protective Order in this case, the materials being produced today
are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,
8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective
Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00010133

Page 2
Bates Start
Bates End
Summary Description
Confidential Designation
SDNY GM 02767074 SDNY GM 02771980 SDFL Files'
Confidential
The Government recognizes tha its discovery obligations are ongoing and will promptly
produce any additional discoverable material of which it becomes aware. Please do not hesitate
to reach out if you have any difficulty accessing these materials.
Very truly …

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