EFTA00025066.pdf

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pdf

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data-set-8

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EXHIBIT 1 
EFTA00025066


U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Si viol Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
October 11, 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. Stemheim 
33 West 19th Street-4th Fl. 
New York, NY 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
Dear Counsel: 
Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government 
writes to inform you that it may refer at trial to the following individuals as co-conspirators of the 
defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E): 
• 
Jeffre E 'stein 
The Government has produced all co-conspirator statements which it intends to offer at 
trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous 
productions. To the extent the Government learns of additional co-conspirator statements as it 
continues to prepare for trial, it will produce those statements in connection with its ongoing 
obligation to produce Jencks Act material. 
EFTA00025067


Page 2 
Please be advised that the above list is limited to the individuals the Government may refer 
to as co-conspirators at trial. While the Government makes no representations as to whether it 
views other individuals as potential or actual co-conspirators of the defendant, it does not intend 
to refer to any other individuals as co-conspirators at trial. The above list is also not intended to 
reflect a complete list of individuals who may be referenced at trial. That information is contained 
in the Government's Jencks Act production(s). 
Please note that this letter and the information contained herein is governed by the July 31, 
2020 Protective Order…

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