U.S. Department of Justice¶
United States Attorney Southern District of New York¶
April 23, 2021¶
BY ELECTRONIC MAIL¶
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:¶
Today we are producing certain materials relating to an expert the Government currently intends to call as a witness at trial in the above-referenced case. Below please find an index detailing the materials included in today’s production. Please note that this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.¶
| 3502 | Date | Description |
| 3502-001 | 2/1/2021 | Interview notes |
| 3502-002 | 2/1/2021 | prior testimony |
| 3502-003 | 3/3/2021 | Interview notes |
| 3502-004 | 4/9/2021 | Interview notes |
| 3502-005 | 4/21/2021 | Interview notes |
| 3502-006 | curriculum vitae | |
| 3502-007 | 3/8/2021 | Contract for services |
EFTA00092513¶
Page 2¶
The Government reserves its right to amend and supplement these disclosures.¶
Very truly yours,¶
United States Attorney¶
EFTA00092514¶