EFTA00017085.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
August 5, 2020
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Counsel:
This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal
Procedure ("Fed. R. Crim. P."), and seeks reciprocal discovery.'
Disclosure by the Government
Based on your request for discovery in this case, enclosed please find copies of the
materials listed in the attached index, which materials are stamped with control numbers
SDNY GM 00000001 through SDNY_GM_00012841. If you wish to inspect any of the physical
evidence referenced in these materials, including items listed on search inventories, please let us
know, and we will make arrangements for you to do so.
The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should not be taken to indicate that the Government believes the enclosed information
constitutes Brady material.
Rather, we make this disclosure in an abundance of caution.
Specifically, the Government discloses the following:
•
The Government will provide material under Giglio v. United States, 405 U.S. 150, 154
(1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by
the Court.
In addition to information provided herein, please note that this Office periodically posts content
on social media platforms including Twitter, Facebook and YouTube. Members of the public may
post comments in response to the Office's postings. We do not control these user-generated
comments, nor do we monitor or regularly review such comments. You may directly access these
social media platforms in the event you believe someone may have posted information relevant to
this case.
06.20.2018
EFTA00017085

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