Counsel,¶
Attached please a discovery production in the above-referenced case and an accompanying cover letter. The password for today’s production is:¶
Best,¶
One St. Andrew’s Plaza New York, New York 10007¶
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¶
February 26, 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 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:¶
Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02742751 through SDNY_GM_02742962.¶
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. An index of the materials contained in this production is below:¶
Files in PDF format designated as “confidential” under the protective order have been stamped “confidential.” However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format.¶
| Bates Start | Bates End | Summary Description | Confidential |
|---|---|---|---|
| Designation | |||
| SDNY_GM_92742751 | SDNY_ GM_ 02742752 | American Express records | |
| SDNY GM 02742753 | SDNY GM 02742754 | Amanda Kramer emails | Confidential |
| SDNY GM 02742755 | SDNY GM 02742762 | A. Kramer emails | |
| Emails between Serene Nakano and | |||
| SDNY_GM_02742763 | SDNY_GM_02742877 | A. Marie Villafana | |
| A. Kramer February 2016 meeting | |||
| SDNY GM 02742878 | SDNY GM 02742886 | notes | Confidential |
| Notes of February 11, 2021 Call with | |||
| SDNY_GM_02742887 | SDNY_GM_02742892 | A. Kramer | |
| Notes from the U.S. Attorney’s | |||
| Office for the Southern District of | |||
| SDNY_GM_02742893 | SDNY_GM_02742894 | Florida | |
| Flight log provided to A. Kramer at | |||
| SDNY GM 02742895 | SDNY GM 02742962 | February 2016 meeting | Confidential |
Among the ma erials contained in this production is an excerpt of a flight log that former Assistant United States Attome received during a February 29, 2016 meeting with attorneys representing the “February 2016 meeting”). At the February 2016 meeting, AUSA deceived copies of Jeffrey Epstein’s black book, excerpts of flight records, and certain Palm Beach Police Department reports. Epstein’s black book and the Palm Beach Police Department reports were previously produced to you on August 21, 2020, and can be found at SDNY_GM_00 174731-SDNY_GM_00 174827 and SDNY_GM_00174880- SDNY_ GM 00174966 respectively. Today we are producing to you the version of the flight recordsAU§A Kramer received at the February 2016 meeting, which includes a subset of logs previously produced to you on August 5, 2020 (see SDNY_GM_00005532- SDNY GM 00005676) as well as two additional pages that were not previously produced to you in discovery, see SDNY_GM_02742935 and SDNY_GM_02742937.¶
Additionally, in recognition of the Government’s obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, we are disclosing the information below. This disclosure should not be taken to indicate that the Government believes the enclosed information constitutes Brady material. Rather, we make this disclosure in an abundance of caution. Specifically, the Government discloses the following:¶
- The witness identified as witness “M” in a 2007 a parte declaration, which you attached as Exhibit B to the Defense Pretrial Motion Number 10 for Bill of Particulars and Pre-Trial Disclosures in this case, is On or about November 14, 2006, was interviewed by the Federal Bureau of Investigation. The notes from that interview contain the following line on page 12: “rumor is that JE is gay,” apparently referring to a rumor regarding Jeffrey Epstein’s sexual orientation. The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to review physical items in the FBI’s custody.
Very truly yours,¶