U.S. Department of Justice
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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 24, 2020 BY EMAIL 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. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: We write to disclose the attached notes and 302s, which are stam d SDNY_GM_00332929 through SDNY_GM_00332942, from interviews of Please note that the Government is designating the contents of this letter and its enclosures as "Confidential" under the Protective Order in this case. by: Very truly yours, AUDREY STRAUSS Acting United States Attorney s/ 06.20.2018 EFTA00097815
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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 April 23, 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 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: Today we are producing certain materials relating to an expert the Government currently intends to call as a witness at trial in the above-referenced case. Below please find an index detailing the materials included in today's production. Please note that this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. The Government reserves its rig
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
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 September 13, 2021 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 Sternheim, Esq. • eim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02753699 through SDNY_GM_02762475. 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 designated as "confidential" under the Protective Order. Recently, the Department of Justice directed this office to cease the dissemination of m
Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 1 of 3
Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 1 of 3 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 1, 2021 VIA 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 submits this letter to bring to the Court's attention an opinion piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's statements in the Op-Ed were in violation of Local Rule 23.1, which contains provisions relating to extrajudicial public statements by attorneys. Accordingly, for the reasons stated below, the Government respectfully requests t
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 25, 2020 BY EMAIL 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. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: We write to disclose the attached notes and 302s, which are stam d SDNY_GM_00332929 through SDNY_GM_00332942, from interviews of Please note that the Government is designating the contents of this letter and its enclosures as "Confidential" under the Protective Order in this case. Very truly yours, AUDREY STRAUSS Acting United States Attorney by: s/ Assistant United States Attorneys (212
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 New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C. Denver, CO 80203 Dear Counsel: The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 January 8, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) We write in response to your letter of December 28, 2020, in which you request a bill of particulars in the above-captioned matter. As set forth herein, the Government does not intend to provide further particulars because under the well-established law of this Circuit it has no obligation to do so. To the contrary, and as you are aware, the Government outlined its charges against your client in a detailed speaking superseding indictment (the "Indictment")
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