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¶
November 24, 2021¶
BY ELECTRONIC MAIL¶
Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP¶
New York, NY 10022¶
Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mo an and Foreman, P.C.¶
Denver, CO 80203¶
Bobbi Sternheim, Esq. Law Offices of Bobbi C. Stemheim¶
New York, NY 10007¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)¶
Dear Counsel:¶
Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02775073 through SDNY_GM_02775777.¶
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. The Department of Justice directed this office to cease the dissemination of materials marked with the word “confidential” in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: “SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17.” This marking directly refers to the specific paragraphs of the Protective Order that govern today’s production.¶
An index of the materials contained in this production is below:¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
|---|---|---|---|
| SDNY_GM_02775073 | SDNY_GM_02775087 | JPMC records | Confidential |
| SDNY_GM_02775088 | SDNY_GM_02775777 | Lockheed Martin records | Confidential |
The Government recognizes tha 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.¶
Very truly yours,¶
DAMIAN WILLIAMS United States Attorney¶
Assistant United States Attorneys¶