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Court filing · Oct. 19, 2020

SDNY discovery production letter to Maxwell's defense counsel, Oct. 19, 2020

Letter from the U.S. Attorney's Office SDNY to Maxwell's defense attorneys transmitting an indexed discovery production under the protective order in United States v. Maxwell.Machine-written summary

U.S. Department of Justice

United States Attorney Southern District of New York

The Si!lo J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007

October 19, 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

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)

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 MMIErhe materials are available for pickup at the U.S. Attorney’s Office in Manhattan.

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:

Bates StartBates EndSummary DescriptionConfidential
Designation
SDNY_GM_00328070SDNY_GM_003280722020.07.02, Aerial Video
SDNY_GM_00328073SDNY_GM_00328092FBI Florida DocumentsConfidential
SDNY_GM_00328093SDNY_GM_00328289FBI NY Documents
SDNY GM 00328290SDNY_GM_00328461Misc. PhotosConfidential

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. Such files include in their electronic names the word “Confidential.”

06.20.2018

SDNY GM 00328462SDNY_GM_00328667PBPD Materials
SDNY GM 00328668SDNY_GM_00329968PBPD MaterialsConfidential
SDNY GM 00329969SDNY_GM_00330052PBPD MaterialsHighly Confidential
SDNY GM 00330053SDNY_GM_00332355PBSA MaterialsConfidential
SDNY GM 00332356SDNY_GM_00332436Scans of FBI Evidence
SDNY GM 00332437SDNY_GM_00332863Scans of FBI EvidenceConfidential
SDNY GM 00332864SDNY_GM_00332869Scans of FBI EvidenceHighly Confidential
SDNY GM 00332870SDNY_GM_00332871Video from Florida
Investigation
Highly Confidential
SDNY GM 00332872SDNY_GM_00332887Videos from Florida
Investigation
Confidential
SDNY GM 00332888SDNY_GM_00332890SDFL MaterialsConfidential
SDNY GM 00332891SDNY_GM_00332891SDFL MaterialsHighly Confidential
SDNY GM 00332892SDNY_GM_00332894FBI Florida Documents
SDNY GM 00332895SDNY_GM_00332928FBI FL Documents (included
with 328073-328092)
Confidential
SDNY_GM_00332943SDNY_GM_003329583-D Blueprints, in PBPD
Materials (included with
328462-328667)
SDNY_GM_00332949SDNY_GM_00356148FBI FL Documents from DiscsConfidential and
Highly Confidential

The Govemmen 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,

06.20.2018

SDNY discovery production letter to Maxwell's defense counsel, Oct. 19, 2020

Court filings

Letter from the U.S. Attorney's Office SDNY to Maxwell's defense attorneys transmitting an indexed discovery production under the protective order in United States v. Maxwell.

DOJ Epstein Files, Data Set 8 · Oct. 19, 2020

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 19, 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 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed i…