EFTA00010162.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 
The Siltio.1. Moll° Building 
One Saint Andrew's Plaza 
New York New York 10007 
November 16, 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 Stemheim, Esq. 
Law Offices of Bobbi C. Sternheim 
33 West 19th Street-4th Fl. 
New York, NY 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Counsel: 
Today the Government is producing additional materials, including Jencks Act and 
Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced 
case. Enclosed please find an index detailing the materials included in today's production. 
The Government is also producing today certain materials relating to individuals the 
Government does not currently intend to call as witnesses at trial in the above-referenced case. 
These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the 
Government does not expect to call these individuals to testify at trial. Instead, these materials 
contain, among other things, certain witness statements. Enclosed please find an index detailing 
these materials. This production should not be taken to indicate that the Government believes it 
has any obligation to provide all of these materials; rather, we make this production as a courtesy. 
Moreover, although the Government presently does not intend to call the individuals listed in the 
enclosed index, we reserve the right to do so and will notify you should the Government determine 
that it intends to call any of these individuals at trial. 
EFTA00010162


Page 2 
Please note that this letter, the enclosed index, and the enclosed materials are governed 
by the July 31, 2020 Protective Order in this case. In particular, the materials are d…

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