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Government memo · March 29, 2021

SDNY letter to Maxwell's defense counsel on Minor Victim-4 discovery, March 2021

Audrey Strauss's SDNY office writes Maxwell's defense counsel listing Bates ranges of discovery relevant to the superseding indictment's Minor Victim-4 allegations.Machine-written summary

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

March 29, 2021

BY ELECTRONIC MAIL

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

Bobbi Sternheim, Esq.

Law Offices of Bobbi C. Sternheim

33 West 19th Street-4th Fl.

New York, NY 10007

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

Dear Counsel:

In light of the return of superseding indictment S2 20 Cr. 330 (AJN) (the “S2 Indictment”), the Government writes to provide you with information regarding the individual identified as Minor Victim-4 in the S2 Indictment. Please note that both this letter is 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. Minor Victim-4 was born in

To assist you in identifying portions of the discovery materials that are relevant to the new allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that relate to Minor Victim-4, which were already produced to you. Please note that this list, which is being provided to you as a courtesy, is not exhaustive and does not include every portion of discovery that is relevant Minor Victim-4.

SDNY_GM_00165560

SDNY_GM_00165644

SDNY_GM_00165654

EFTA00099164

Page 2

  • SDNY_GM_00165656 - SDNY_GM_00165659
  • SDNY_GM_00165669 - SDNY_GM_00165670*

SDNY_GM_00165674

SDNY_GM_00165691 - SDNY_GM_00165692

SDNY_GM_00165701

SDNY_GM_00165752

SDNY_GM_00165776

  • SDNY_GM_00365036 - SDNY_GM_00365049
  • SDNY_GM_00381010 – SDNY_GM_00381013*
  • SDNY_GM_00381020 – SDNY_GM_00381023

SDNY_GM_00394866

SDNY_GM_00431558

SDNY_GM_00449302

  • SDNY_GM_00459391

SDNY_GM_00459405

SDNY_GM_00459416

SDNY_GM_00459430

SDNY_GM_00459444

SDNY_GM_00459455

  • SDNY_GM_00525482*

SDNY_GM_01987478

SDNY_GM_02735989

  • SDNY_GM_02742303 - SDNY_GM_2742395

  • SDNY_GM_02743100

Very truly yours,

AUDREY STRAUSS

United States Attorney

Assistant United States Attorneys

EFTA00099165

SDNY letter to Maxwell's defense counsel on Minor Victim-4 discovery, March 2021

Government memos

Audrey Strauss's SDNY office writes Maxwell's defense counsel listing Bates ranges of discovery relevant to the superseding indictment's Minor Victim-4 allegations.

DOJ Epstein Files, Data Set 9 · March 29, 2021

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 March 29, 2021 BY ELECTRONIC MAIL 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 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In light of the re…