U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007¶
September 14, 2020¶
BY EMAIL¶
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 (AJN)¶
Dear Counsel:¶
Please note that the Government is designating the contents of this letter and its enclosures as “Confidential” under the Protective Order in this case. In recognition of the Government’s obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, we write to disclose the following information, in connection with the pending charges against your client, which the defendant may wish to argue is in some way helpful to the defense. This disclosure should not be taken to indicate that the Government believes the enclosed information is exculpatory.¶
During its investigation into the charges contained in the indictment in this case, the Government interviewed on two occasions. The notes and 302s from those two interviews are enclosed. Please note that the Government is also designating those items as “Confidential” under the Protective Order in this case.¶
Very truly yours,¶
AUDREY STRAUSS¶
Acting United States Attorney¶
by:¶
- 20.2018
EFTA00078980¶