EFTA00010160.pdf

94 KB

Extraction Summary

7
People
6
Organizations
4
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / discovery production letter
File Size: 94 KB
Summary

This document is a letter dated November 16, 2021, from U.S. Attorney Damian Williams to the defense counsel for Ghislaine Maxwell. It serves as a cover letter for the production of discovery materials, specifically AT&T records, phone records, and photographs, noting that these materials are subject to a protective order.

People (7)

Name Role Context
Damian Williams United States Attorney
Sender of the letter, representing the Southern District of New York.
Ghislaine Maxwell Defendant
Subject of the case 'United States v. Ghislaine Maxwell'.
Christian Everdell Defense Counsel
Recipient of the letter, attorney at Cohen & Gresser LLP.
Mark Cohen Defense Counsel
Recipient of the letter, attorney at Cohen & Gresser LLP.
Laura Menninger Defense Counsel
Recipient of the letter, attorney at Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca Defense Counsel
Recipient of the letter, attorney at Haddon, Morgan and Foreman, P.C.
Bobbi Sternheim Defense Counsel
Recipient of the letter, attorney at Law Offices of Bobbi C. Sternheim.

Organizations (6)

Name Type Context
U.S. Department of Justice
Government agency issuing the letter.
United States Attorney's Office Southern District of New York
Specific office handling the prosecution.
Cohen & Gresser LLP
Law firm representing the defendant.
Haddon, Morgan and Foreman, P.C.
Law firm representing the defendant.
Law Offices of Bobbi C. Sternheim
Law firm representing the defendant.
AT&T
Company whose records are being produced in discovery.

Timeline (1 events)

2021-11-16
Production of discovery materials by the US Government to the defense team.
New York, NY
US Attorney's Office Defense Counsel

Locations (4)

Location Context
Address of the US Attorney's Office in New York.
Address of the US Attorney's Office in New York.
Location of DOJ office and Cohen & Gresser LLP.
Location of Haddon, Morgan and Foreman, P.C.

Relationships (2)

Damian Williams Prosecutor/Defendant Ghislaine Maxwell
Williams is the US Attorney prosecuting the case against Maxwell.
Christian Everdell Attorney/Client Ghislaine Maxwell
Everdell is addressed as counsel in the case United States v. Ghislaine Maxwell.

Key Quotes (3)

"Today we are producing the materials listed in the below index."
Source
EFTA00010160.pdf
Quote #1
"This letter is itself designated as 'confidential,' because it includes information regarding records designated as 'confidential' under the Protective Order."
Source
EFTA00010160.pdf
Quote #2
"The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware."
Source
EFTA00010160.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,383 characters)

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
November 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 materials are stamped with control numbers SDNY_GM_02771984 through SDNY_GM_02772261.
Please note that both this letter and the enclosed materials are 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. The Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production.
An index of the materials contained in this production is below:
EFTA00010160
Page 2
Bates Start | Bates End | Summary Description | Confidential Designation
--- | --- | --- | ---
SDNY_GM_02771984 | SDNY_GM_02772047 | AT&T records | Confidential
SDNY_GM_02772048 | SDNY_GM_02772257 | Phone records | Confidential
SDNY_GM_02772258 | SDNY_GM_02772261 | Photographs |
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,
DAMIAN WILLIAMS
United States Attorney
by: s/
[REDACTED SIGNATURE BLOCK]
Assistant United States Attorneys
EFTA00010161

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