EFTA00025287.pdf

Type

pdf

Source set

data-set-8

Original source

Extracted text

rot 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio J. Motto Building 
One Saint Andrew's Plaza 
New York. New York 10007 
October 11, 2021 
BY ELECTRONIC MAIL 
Esq. 
E. . 
New York, NY 10022 
Esq. 
Denver, CO 80203 
Es . 
w 
ices o 
ew ork. NY 10007 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 
Dear Counsel: 
Today the Government is producing materials, including Jencks Act and Giglio 
material, regarding the 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 notes that the records stamped 3522-004 reflect tha 
testified in the grand jury in connection with the investigation conducted by the Pam eac 
tate s 
Attorney's Office, but the clerk of court has c 
Government that the audio files are 
unplayable and, therefore, there is no record o 
nd jury testimony. 
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 
EFTA00025287


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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. 
miii 
The Govern 
' 
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