EFTA01325071
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
COHEN & GRESSER LLP
ANnW COHEN & GRESSER LLP October 13, 2020 BY EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear ..,-:,w.cohengessercom We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of October 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by
Maxwell Brief
Case 18-2868, Document 279, 08/09/2019, 2628231, Page1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. ............................................. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS --------------------------------------------------X Reply Brief in Support of Defendant’s Motion for Summary Judgment Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,
COHEN & GRESSER LLP
GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of
COHEN & GRESSER LLP
COHEN & GRESSER LLP .,:m.cohengesser <cm October 13, 2020 BY EMAIL United States Attorney's Office w York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of October 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceed
Florida Office
Ll Florida Office Bradley J. Edwards "Of Seth M. Lehrman "t Brittany N. Henderson "0 Matthew D. Weissing "I VIA E-MAIL AND FEDEX The Honorable United States Attorney for the Southern District of New York Chief, Civil Division U.S. Attorney's Office, SDNY 86 Chambers Street, 3nd Floor New York, NY 10007 Elm EDWARDS POTTINGER LLC September 14, 2021 FOIA PRIVACY EXEMPTION New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida j Admitted in New York Heard Certified Civil Trial lawFr Re: Request for Tangible and Documentary Evidence (Touhy Request) Lola Doe v. Darren K. Indyke, et al., SDNY Case No. 1:21-cv-03876 Dear Mr. Please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many v
EFTA01651997
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