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Correspondence · Aug. 5, 2020

SDNY discovery letter to Maxwell's defense lawyers in U.S. v. Maxwell, Aug. 2020

SDNY prosecutors transmit initial discovery to Ghislaine Maxwell's defense counsel, listing records including travel, financial, and flight manifest materials.Machine-written summary

U.S. Department of Justice

United States Attorney Southern District of New York

August 5, 2020

By Email & Hand

Christian Everdell, Esq.

Mark Cohen, Esq.

Cohen & Gresser LLP

Laura Menninger, Esq.

Jeffrey Pagliuca, Esq.

Haddon, Morgan and Foreman, P.C.

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

Dear Counsel:

This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure (“Fed. R. Crim. P.”), and seeks reciprocal discovery. $ ^{1} $

Disclosure by the Government

Based on your request for discovery in this case, enclosed please find copies of the materials listed in the attached index, which materials are stamped with control numbers SDNY_GM_00000001 through SDNY_GM_00012841. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. $ ^{2} $

1 In addition to information provided herein, please note that this Office periodically posts content on social media platforms including Twitter, Facebook and YouTube. Members of the public may post comments in response to the Office’s postings. We do not control these user-generated comments, nor do we monitor or regularly review such comments. You may directly access these social media platforms in the event you believe someone may have posted information relevant to this case.

$ ^{2} $ 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,” and, additionally, the bates numbers for confidential files that could not be individually labeled are included in the table below.

06.20.2018

EFTA00040593

Page 2

This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order.

The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court.

Disclosure by the Defendant

In light of your request for discovery in this case, the Government hereby requests reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of: (1) any books, or copies or portions thereof, which are in the defendant’s possession, custody or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental examinations and of scientific tests or experiments made in connection with this case, or copies thereof, which are in the defendant’s possession or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the defendant intends to call at trial.

The Government also requests that the defendant disclose prior statements of witnesses he will call to testify. See Fed. R. Crim. P. 26.2; United States v. Nobles, 422 U.S. 225 (1975). We request that such material be provided on the same basis upon which we agree to supply the defendant with 3500 material relating to Government witnesses.

Sentence Reduction for Acceptance of Responsibility

This Office will oppose the additional one-point reduction under the Sentencing Guidelines available for defendants who plead prior to the Government’s initiation of trial preparations pursuant to U.S.S.G. § 3E1.1(b), in the event your client has not entered a plea of guilty six weeks prior to trial, or prior to the provision of 3500 material, whichever is earlier. We will follow this policy whether or not suppression or other pretrial motions remain outstanding after this date and even if the trial date has not been announced by the Court six weeks in advance of the trial.

Finally, please be advised that pursuant to the policy of the Office concerning plea offers, no plea offer is effective unless and until made in writing and signed by authorized representatives of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not reduced to writing and signed by authorized representatives of the Office cannot and do not constitute a “formal offer” or a “plea offer,” as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012).

06.20.2018

EFTA00040594

Page 3

Bates StartBates EndConfidential Non-PDF FilesSummary DescriptionDesignation
SDNY_GM_00000001SDNY_GM_00000002Ghislaine Maxwell Joint Automated Booking System Summary
SDNY_GM_00000003SDNY_GM_00000004Pen Register Orders and Applications
SDNY_GM_00000045SDNY_GM_00000717Search Warrants and ApplicationsConfidential
SDNY_GM_00000718SDNY_GM_00000833Immigration and Travel Records for Jeffrey Epstein and Ghislaine Maxwell
SDNY_GM_00000834SDNY_GM_00000905Unsealing materials pertaining to 15 Civ. 7433 (RWS), 19 Misc. 149 (CM)Confidential
SDNY_GM_00000906SDNY_GM_00000962Unsealing materials pertaining to 17 Civ. 0616 (SN), 19 Misc. 179 (SN)Confidential
SDNY_GM_00000963SDNY_GM_00000964SDNY_GM_00000963Airline Reporting Corporation recordsConfidential
SDNY_GM_00000965SDNY_GM_00000965Alaska Airlines recordsConfidential
SDNY_GM_00000966SDNY_GM_00000976SDNY_GM_00000967; SDNY_GM_00000969; SDNY_GM_00000971; SDNY_GM_00000973; SDNY_GM_00000974; SDNY_GM_00000976Amazon RecordsConfidential
SDNY_GM_00000977SDNY_GM_00001012American Airlines recordsConfidential
SDNY_GM_00001013SDNY_GM_00001014SDNY_GM_00001014Apple Records for Jeffrey EpsteinConfidential
SDNY_GM_00001015SDNY_GM_00003637AT&T RecordsConfidential
SDNY_GM_00003638SDNY_GM_00003701Bank of America RecordsConfidential
SDNY_GM_00003702SDNY_GM_00003702Century Link Records for the numberConfidential
SDNY_GM_00003703SDNY_GM_00004639SDNY_GM_00004511Citibank RecordsConfidential
SDNY_GM_00004640SDNY_GM_00004649Delaware Division of Corporations Records relating to LSJ LLC
SDNY_GM_00004650SDNY_GM_00004655Delta Airlines RecordsConfidential
SDNY_GM_00004656SDNY_GM_00004656School RecordsConfidential
SDNY_GM_00004657SDNY_GM_00004657Expedia Records
SDNY_GM_00004658SDNY_GM_00004721Experian RecordsConfidential
SDNY_GM_00004722SDNY_GM_00004762Gold Coast Federal Credit Union recordsConfidential
SDNY_GM_00004763SDNY_GM_00004776Google records regarding account information for Jeffrey Epstein and Ghislaine MaxwellConfidential
SDNY_GM_00004776SDNY_GM_00004781Instagram records

06.20.2018

EFTA00040595

Page 4

RecordsConfidential
SDNY_GM_00004782SDNY_GM_00005414
SDNY_GM_00005415SDNY_GM_00005416MCC Request for Emails
SDNY_GM_00005417SDNY_GM_00005417Microsoft Records regarding account information for Jeffrey Epstein
SDNY_GM_00005418SDNY_GM_00005444MoneyGram Records relating to Ghislaine Maxwell, andConfidential
SDNY_GM_00005445SDNY_GM_00005484New York State Department of State records
SDNY_GM_00005485SDNY_GM_00005491Oath Holdings records for Jeffrey Epstein email accountsConfidential
SDNY_GM_00005492SDNY_GM_00005531School RecordsConfidential
SDNY_GM_00005532SDNY_GM_00005676Flight manifests and records from David Rodgers, 1991 - 2013Confidential
SDNY_GM_00005677SDNY_GM_00006060Charles Schwab RecordsConfidential
SDNY_GM_00006061SDNY_GM_00006079Shoppers Travel RecordsConfidential
SDNY_GM_00006080SDNY_GM_00006096Southwest RecordsConfidential
SDNY_GM_00006097SDNY_GM_00006129Capital One RecordsConfidential
SDNY_GM_00006130SDNY_GM_00007425TD Bank RecordsConfidential
SDNY_GM_00007426SDNY_GM_00007641PayPal RecordsConfidential
SDNY_GM_00007642SDNY_GM_00007677T-Mobile recordsConfidential
SDNY_GM_00007678SDNY_GM_00008136Materials from Darren Indyke and Richard Kahn (Epstein Estate Executors)Confidential
SDNY_GM_00008137SDNY_GM_00008137UMB Bank no records notificationConfidential
SDNY_GM_00008138SDNY_GM_00008146United Airlines recordsConfidential
SDNY_GM_00008147SDNY_GM_00010164UBS Bank recordsConfidential
SDNY_GM_00010165SDNY_GM_00010355USAA records

06.20.2018

EFTA00040596

Page 5

SDNY_GM_00010356SDNY_GM_00010456U.S. Virgin Islands Division of Corporations records for Laurel Inc, Maple Inc, and Nautilus, IncConfidential
SDNY_GM_00010457SDNY_GM_00010459Venmo recordsConfidential
SDNY_GM_00010460SDNY_GM_00010461Verizon recordsConfidential
SDNY_GM_00010462SDNY_GM_00011483Flight manifest records from Lawrence VisokiConfidential
SDNY_GM_00011484SDNY_GM_00011488Western Union record of no accounts foundConfidential
SDNY_GM_00011489SDNY_GM_00012474SDNY_GM_00011489; SDNY_GM_00011490; SDNY_GM_00012217; SDNY_GM_00012220; SDNY_GM_00012305; SDNY_GM_00012359; SDNY_GM_00012382; SDNY_GM_00012396; SDNY_GM_00012405; SDNY_GM_00012435TD Ameritrade MaterialsConfidential
SDNY_GM_00012475SDNY_GM_00012841Materials fromConfidential

Very truly yours,

Acting United States Attorney

Enclosure

06.20.2018

EFTA00040597

SDNY discovery letter to Maxwell's defense lawyers in U.S. v. Maxwell, Aug. 2020

Emails and letters

SDNY prosecutors transmit initial discovery to Ghislaine Maxwell's defense counsel, listing records including travel, financial, and flight manifest materials.

DOJ Epstein Files, Data Set 9 · Aug. 5, 2020

U.S. Department of Justice United States Attorney Southern District of New York August 5, 2020 <u By Email & Hand</u Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure (“Fed. R. Crim. P.”), and seeks reciprocal discovery. $ ^{1} $ Disclosure by the Government Based on your request for discovery in this case, enclosed please find copies of th…