EFTA00019599.pdf

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pdf

Source set

data-set-8

Original source

Extracted text

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 
March 29, 2021 
BY ELECTRONIC MAIL 
Christian Everdell, Esq. 
Mark Cohen, 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. Stemheim 
33 West 19th Street-4th Fl. 
New York, NY 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Counsel: 
We write in response to your March 8, 2021 letter, which requests the disclosure of: 
(1) documents produced to Radar Online in the matter of Radar Online v. FBI, 17 Civ. 3956 
(PGG); (2) "any other FOIA requests that have produced documents pertaining to any investigation 
of Jeffrey Epstein or Ghislaine Maxwell"; and (3) "any materials that reflect the involvement of 
the FBI-New York Office in the USAO-SDFL investigation." We address each request in turn 
below. 
First, you have requested that we produce to you all materials that were produced to Radar 
Online pursuant to the Freedom of Information Act ("FOIA") in connection with the civil lawsuit 
Radar Online v. FBI, 17 Civ. 3956 (PGG). As an initial matter, your letter fails to articulate any 
legal basis for that request under Rule 16, or any other law governing criminal discovery. 
Moreover, to the extent that you assert that you need to know when information received by Radar 
Online through FOIA may have been published by the media, any information about the date of 
publication would presumably be publicly available and, in any event, not information within the 
Government's possession, custody or control. 
EFTA00019599


Page 2 
Notwithstanding the above, we have been informed by an attorney in the General Counsel's 
Office of the Federal Bureau of Investigation that all materials produced pursuant to the FOIA …

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