(USANYS)"
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From: (USANYS)" To: Christian Everdell , "bcstemhei , Laura Menninger , Jeff Pagliuca C USANYS) [Contractor]" Subject: US v. Maxwell, 20 Cr. 330 (AJN) Date: Ilte, 23 Nov 2021 14:08:08 +0000 Attachments: 2021.11.23_Maxwell_Discovety_Letter.pdf; 2021.11.23_Maxwell_3500_Cover Letter.pdf; 202I.11.23_U.S._v_Maxwell_3500_Index_(Defense).pdf; 2021.11.23_U.S._v_Maxwell_Non-Testifying_Witness_Materialindex_(Defense).pdf; 2021.11.23_US_v._Maxwell_Government_Exhibit_IndexiDefense).pdf Counsel, We have an additional discovery production ready to send to you. Attached please find the accompanying cover letter. In addition, a supplemental production of testifying witness and non-testifying witness material and exhibits are also ready to send to you. Attached please find the accompanying cover letter and indices. The production will be made via USAfx. We will bring a disc to court today for Ms. Maxwell. Assistant United States Attorney United States Attorney's Office Southern Dis
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U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 4, 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 (AJN) Dear Counsel: Pursuant to the Court's November I, 2021 order, we write to provide you with categories and exemplars of statements that are admissible as co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E). Because no attorney can predict the verbatim testimony of a witness, please note that the following statements are simply the Government's understanding of the sum and substance of the statement. A
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
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
mid Avenue
mid Avenue COHEN & GRESSER LLP October 13, 2020 BY EMAIL , Esq. Esq. Esq. United States Attorney's Office Southern District of New York New York, NY 10007 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
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
U.S. Department of Justice
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. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16(a)(1)(G) of the Federal Rules of Criminal Procedure, the Government hereby provides notice that it may call as an expert witness at trial Dr. a clinical instructor of psychiatry and human behavior at the Alpert Medical School of Brown University. The Government reserves the right to call additional expert witnesses and will promptly provide notice if the Government elects to do so. I. Disclosure by the Government is the President-Elect of the Division of Trauma Psychology of the American Psychological Association ("APA"). Dr. has practiced psychology since earning her
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