COHEN & GRESSER LLP
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COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-76IX) [email protected] December 10, 2021 BY EMAIL nited tates Attorney's O ice Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case. 2. Richard Barnett r. ar le z 2063779.1 EFTA00155647 December Iu, Page 2 II. Ryan Dionne 12. 13. Brad
Persons Referenced (8)
“...ubject to briefing prior to any testimony) 31. Doug Schoettle 32. 33. 34. Igor Zinoviev 35. Shopper's Travel records custodian In the email accompanying this letter, we have also provided a h...”
Jack Scarola“.... Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering thei...”
Bradley EdwardsCHRISTIAN R. EVERDELLROBERT GLASSMANUnited StatesPotential Defense WitnessesGhislaine Maxwell“...ict of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we w...”
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COHEN & GRESSER LLP
COHEN & GRESSER LLP December 10, 2021 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, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case. 1. • 2. 3. 4. 5. 6. 7. 8. Task Force Office 9. Lucy Mary Clive 10. Dr. Park Dietz 2063779.1 EFTA00156482 December 10, 2021 Page 2 11. 12. 13. Brad Edwards (atto
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
COHEN & GRESSER LLP
COHEN & GRESSER LLP Thrd Avenue I ow York. NY 10022 October 13, 2020 BY EMAIL United States Attorney's Office 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 ca
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