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Correspondence · March 16, 2021

SDNY letter to Maxwell's defense counsel producing FBI seizure manifests, Mar. 2021

SDNY prosecutors notify defense counsel in United States v. Maxwell of a discovery production of FBI seizure manifests under a protective order.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 16, 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:

Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02743101 through SDNY_GM_02743102. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. $ ^{1} $ This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order. An index of the materials contained in this production is below:

Bates StartBates EndSummary DescriptionConfidential Designation
SDNY_GM_02743101SDNY_GM_02743101Manifest of items seized by FBI FloridaConfidential

$ ^{1} $ 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.

EFTA00103621

Page 2

SDNY_GM_02743102SDNY_GM_02743102Manifest of items seized by FBI New YorkConfidential

The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials.

Very truly yours,

EFTA00103622

SDNY letter to Maxwell's defense counsel producing FBI seizure manifests, Mar. 2021

Emails and letters

SDNY prosecutors notify defense counsel in United States v. Maxwell of a discovery production of FBI seizure manifests under a protective order.

DOJ Epstein Files, Data Set 9 · March 16, 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 16, 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: Today we are produ…