U.S. Department of Justice
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U.S. Department of Justice United States Attorney Southern District of New York The Siltio.1. MoNo Building One Saint Andrew's Plaza New York New York 10007 November 24, 2021 VIA FEDERAL EXPRESS MDC—Metropolitan Detention Center Legal Department Brooklyn, NY 11232 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) The password for the drive containing witness materials, government exhibits, and discovery pertinent to Ghislaine Maxwell (02879-509) is 5634536 Very tnily yours, DAMIAN WILLIAMS United States Attorney by: /s Assistant United States Attorneys EFTA00073589
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. EFTA00099019 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006 may be received in evidence at trial. Dated: November 2021 New York, New York DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: Ass
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully requests permission to file a reply brief in support of the Government's motion to preclude the testimony of Dr. Ryan Hall. Among other issues, the defendant's opposition brief raises new arguments about hearsay exceptions that the defendant argues apply to information contained in Dr. Hall's report and further elaborates on the defendant's theory of the report's relevance. The Government proposes to file its responsive brief by noon on November 22, 2021, and to respond only regarding Dr. Hall and not the other experts discussed
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Moll° Building One Saint Andrew's Plaza New York. New York 10007 December 17, 2020 BY FEDERAL EXPRESS MDC—Metropolitan Detention Center Legal Department 80 29th Street Brooklyn, NY 11232 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Enclosed is discovery pertinent to the following inmate: • Ghislaine Maxwell: 02879-509 Please allow her access to the materials enclosed. by: Enclosure Very truly yours, AUDREY STRAUSS Acting United States Attorney Assistant United States Attorneys EFTA00078333
U.S. Department of Justice
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 August 9, 2021 VIA FEDERAL EXPRESS MDC—Metropolitan Detention Center Legal Department 80 29'h Street Brooklyn, NY 11232 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Enclosed is discovery pertinent to the following inmate: • Ghislaine Maxwell: 02879-509 Please allow her access to the materials enclosed. Very truly yours, AUDREY STRAUSS United States Attorney Enclosure Assistant United States Attorneys EFTA00086766
U.S. Department of Justice
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 28, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, 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: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records design
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