EFTA00025035.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 Silvio J. Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
October 25, 2021 
BY ELECTRONIC MAIL 
Christian Everdell, Esq. 
Cohen & Gresser LLP 
New York, NY 10022 
Laura Menninger, Esq. 
Jeffrey Pagliuca, Esq. 
Haddon, Morgan and Foreman, P.C. 
Denver, CO 80203 
Bobbi Stemheim, Esq. 
Law Offices of Bobbi C. Stemheim
New York, NY 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
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. Please note that the records stamped 3501.507 through 3501.516 were previously 
produced to you on October 11, 2021 with a different stamp (3501.450 through 3501.459), which 
was inadvertently used for two sets of witnesses. The Government is reproducing the materials to 
avoid any confusion. 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 
EFTA00025035


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enclosed index, we reserve the right to do so and will notify you should the Government determine 
that it intends …

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