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efta-efta00090463DOJ Data Set 9Other

EXHIBIT A

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00090463
Pages
3
Persons
8
Integrity
No Hash Available

Summary

EXHIBIT A EFTA00090463 U.S. Department of Justice United States Attorney Southern District of New York The SiMoJ. Mono Building One Saint Andrew's Plana New York, New York 10007 October 11. 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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In i articular. the Government ma offer certain exhibits at trial that demonstrate that. We are producing t ese propos e 'its t y, i . : GX 401 through 404, GX 409 through 410, and GX 413. wr i tie o owing e it In addition, please be advised that the Government may call as a witness

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
EXHIBIT A EFTA00090463 U.S. Department of Justice United States Attorney Southern District of New York The SiMoJ. Mono Building One Saint Andrew's Plana New York, New York 10007 October 11. 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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In i articular. the Government ma offer certain exhibits at trial that demonstrate that. We are producing t ese propos e 'its t y, i . : GX 401 through 404, GX 409 through 410, and GX 413. wr i tie o owing e it In addition, please be advised that the Government may call as a witness at trial. Today, we are producing Jencks Act materials relating to , w o was e lo ed by Jeffrey Epstein from The Government anticipates that will testify about, among other things, certain documentary evidence relating to e c g crimes. The Government further anticipates that will testify about her role in scheduling sexualized massages for Jeffrey Epstein with un erage girls. EFTA00090464 Page 2 This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of accident with respect to the charges in the above-referenced case. Because this evidence is admissible as direct evidence, the Government is not planning to affirmatively move in limine to seek its admission. Please note that this letter and the information contained herein is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential" under the Protective Order. Very truly yours, DAMIAN WILLIAMS United States Attorney by: /s Assistant United States Attorneys EFTA00090465

Related Documents (6)

DOJ Data Set 9OtherUnknown

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: I. The document marked SDNY_GM_000143740 through SDNY_ GM_ 00144203 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on April 22, 2016, in New York, New York. 2. The document marked SDNY_GM_00144204 through SDNY_ GM _00144423 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on July 22, 2016, in New York, New York.

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DOJ Data Set 9OtherUnknown

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: I. Government Exhibit 551 is a true and correct copy of records from AT&T Corporation ("AT&T"), a telephone service provider. Government Exhibit 551 contains billing records for a cellular telephone number. The records reflected in Government Exhibit 551 were created by a person with knowledge of, or created from information transmitted by a person with knowledge of, the information shown; were created at or near the time the i

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DOJ Data Set 9OtherUnknown

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: I. The documents marked 3505-043 and 3505-044 are a true and accurate copy of the transcript of the deposition taken on December 4, 2009 in West Palm Beach, Florida. EFTA00090937 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1007, and the documents marked 3505-043 and 3505-044, may be received in evidence as Government exhibits at trial subject to objections by the defense based on rel

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DOJ Data Set 9OtherUnknown

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 20, 2020 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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_00328070 through SDNY_GM_00356148. The password for the drive is "USAOsdnyl!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this l

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DOJ Data Set 9OtherUnknown

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: I. The document marked SDNY_GM_000143740 through SDNY_ GM_ 00144203 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on April 22, 2016, in New York, New York. 2. The document marked SDNY_GM_00144204 through SDNY_ GM _00144423 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on July 22, 2016, in New York, New York. EFTA0

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DOJ Data Set 9OtherUnknown

Juror ID:

FINAL Juror ID: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA -V- GHISLAINE MAXWELL, Defendant. INSTRUCTION SHEET Dear Juror: X 20 Cr. 330 (MN) JURY QUESTIONNAIRE Please call on November 15, 2021 after 6:00 p.m. for further reporting instructions. Please bring this instruction sheet with you to the courthouse if you are instructed to return. -1- EFTA00077967 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CONSTANCE BAKER MOTLEY JURY ASSEMBLY ROOM 160 SECTION I: JUROR INFORMATION ALL FIELDS IN THIS SECTION MUST BE COMPLETED TO ENSURE YOU RECEIVE YOUR PAYMENT FOR SERVICE Full Name: •Address: Home Phone # Last Fiat M I. Street Address City State Zip Code Aportment/Unit Business Phone I Cell Phone I *NO P.O. BOXES. YOU MUST PROVIDE A RESIDENTIAL ADDRESS FOR MILEAGE REIMBURSEMENT. Social Security # PLEASE SELECT ONE NOTE: ATTENDANCE LETTERS WILL BE MAILED 21 DAYS AFTER SERVICE PRINT ATTENDANCE LET

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