EXHIBIT A¶
United States Attorney Southern District of New York¶
The SifnoJ. Motto Building One Saint Andrea s Plaza New York Net York 10007¶
October 11. 2021¶
BY ELECTRONIC MAIL¶
Christian Everdell, Esq.¶
& Gresser LLP¶
800 Third Avenue¶
New York, NY 10022¶
Laura Menninger, Esq.¶
Jeffrey Pt a. Esq.¶
Haddon, and 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:¶
We write to notify you that the Government may seek to introduce certain evidence at trial. In r articular the Government ma offer certain exhibits at trial that demonstrate that.¶
We are pr zing t ese prop° e its t y, rs: GX 401 through 404, GX 409 through 410, and GX 413. e o owing e¶
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 ocument evidence relating to e c g crimes. The Government further anticipates that will testify about her role in scheduling sexualized massages for Jeffrey Epstein wit un erage girls.¶
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 United States Attorney¶
by: /s¶
Alison Moe Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys (212) 637-2324¶