rot U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Silvio J. Motto Building One Saint Andrew’s Plaza New York. New York 10007¶
October 11, 2021¶
BY ELECTRONIC MAIL¶
ew ork. NY 10007¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)¶
Dear Counsel:¶
Today the Government is producing materials, including Jencks Act and Giglio material, regarding the witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today’s production.¶
The Government notes that the records stamped 3522-004 reflect tha testified in the grand jury in connection with the investigation conducted by the Pam eac tate s Attorney’s Office, but the clerk of court has c Government that the audio files are unplayable and, therefore, there is no record o nd jury testimony.¶
The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial. Instead, these materials contain, among other things, certain witness statements. Enclosed please find an index detailing these materials. This production should not be taken to indicate that the Government believes it¶
has any obligation to provide all of these materials; rather, we make this production as a courtesy. Moreover, although the Government presently does not intend to call the individuals listed in the enclosed index, we reserve the right to do so and will notify you should the Government determine that it intends to call any of these individuals at trial.¶
The Govern miii ’ highlight for you a particular portion of statements made by non-testifying witness about Minor Victim-4. In particul viously stated to law enforcement in sum an substance, that Minor Victim-4 introduced o Jeffrey M i and instructed to tell Epstein that was 18 years old. These statements by are contained in the Government’s non-testy prig witness productions, including in the first such production dated April 12, 2021 (see, e.g., 3501.149-023 at I; 3501.149-026 at 9; and 3501.149-024 between approximately timestamp 04:20 and timestamp 07:30).¶
Please note that this letter, the enclosed indices, and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. In particular, the entire production is designated as “confidential” under the Protective Order. The index 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.¶
Additionally, please note that many of the individuals referenced in this production are represented by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures.¶
The Government also writes to notify you of the following matters regarding certain witnesses that the Government may call to testify at trial in the above-referenced case:¶
| • | ||
|---|---|---|
| o | le FB provided transportation to and from the airport for trial reparation | |
| sessions. The FBI will similarly provide transportation fo when she | ||
| travels to New York for trial testimony. | ||
| o | The U.S. Attorney’s Office for the Southern District of New York (the “USAO | |
| SDNY”) paid for travel to and from a trial preparation session, including hotel | ||
| The USAO SDNY will similarly pay travel and hotel expenses when | ||
| avels to New York to testif at trial. | ||
| o | The USAO SDNY paid fo to | |
| or trial accompany re aration sessions in New | ||
| York. The USAO SD | ||
| lip o New York in connection with to accompany | ||
- o The USAO SDNY will pay travel and hotel expenses when travels to New York to testify at trial.
- o The USAO SDNY provided a letter to mployer confirming dates of trial preparation sessions and has ag to similarly provide a letter to his employer regarding dates of future trial preparation sessions and trial testimony.
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- o The USAO SDNY paid for= to travel to and from a trial preparation session in New York, including hotel ex Phe USA() SDNY will similarly pay travel and hotel expenses whe travels to New York to testify at trial.
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•¶
- o ille USAO SDNY paid for to travel to and from two trial preparation sessions in New York, including hotel exp e USAO SDNY will similarly pay travel and hotel expenses when ravels to New York to testify at trial.
- o The USAO SDNY paid for -to travel to and from a trial preparation session in New York, including hotel expenses. e USAO SDNY will similarly pay travel and hotel expenses whe travels to New York to testify at trial.
- specialists to all victims, including The victim services offered included counseing, assistance wit finding appropriate therapy, and assistance with determining available public benefits and other resources available to crime victims.
- The USAO SDNY has offered—or will offer—to provide transportation to and/or from and hotel accommodations in New York City in connection with the trial testimony of the witnesses the Government anticipates testifying at the trial. Such arrangements have not yet been finalized. The USAO SDNY anticipates that it will pay travel and hotel expenses for trial testimony for at least the following individuals:
Very truly yours,¶
DAMIAN WILLIAMS United States Attorney¶
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