Memorandum of Law in Support of Motion to Dismiss: 138

[REDACTED - Survivor] Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition [REDACTED - Survivor] 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 2, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, N Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Mor an and Foreman, P.C. Denver, CO Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 000174967 through SDNY_GM_ 00328863. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan. 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 i

U.S. Department of Justice

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 October 28, 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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073. 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 design

EFTA00020978

EFTA00018663