EFTA00026913.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of Justice
United States Attorney
Southern District of New York
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon Mor an and Foreman, P.C.
Bobbi Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
April 12, 2021
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing certain materials relating to individuals the Government does not
currently intend to call as witnesses at trial in the above-referenced case. Attached please find an
index detailing the materials included in today's production. Please note that both the index and
the enclosed materials are governed by the July 31, 2020 Protective Order in this case. The index
is itself designated as "confidential," because it includes information regarding records
designated as "confidential" under the Protective Order. Please note that many of these
individuals are represented by counsel, as detailed in the attached index. The Government reserves
its right to amend and supplement these disclosures.
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
EFTA00026913

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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.
Very truly yours,
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00026914

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