EXHIBIT A
EXHIBIT A EFTA00090463 U.S. Department of Justice United States Attorney Southern District of New York The SiMoJ. Mono Building One Saint Andrew's Plana New York, New York 10007 October 11. 2021 BY ELECTRONIC MAIL Christian Everdell, 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 (MN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In i articular. the Government ma offer certain exhibits at trial that demonstrate that. We are producing t ese propos e 'its t y, i . : GX 401 through 404, GX 409 through 410, and GX 413. wr i tie o owing e it In addition, please be advised that the Government may call as a witness
Summary
EXHIBIT A EFTA00090463 U.S. Department of Justice United States Attorney Southern District of New York The SiMoJ. Mono Building One Saint Andrew's Plana New York, New York 10007 October 11. 2021 BY ELECTRONIC MAIL Christian Everdell, 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 (MN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In i articular. the Government ma offer certain exhibits at trial that demonstrate that. We are producing t ese propos e 'its t y, i . : GX 401 through 404, GX 409 through 410, and GX 413. wr i tie o owing e it In addition, please be advised that the Government may call as a witness
Persons Referenced (5)
“...f designated as "confidential" under the Protective Order. Very truly yours, DAMIAN WILLIAMS United States Attorney by: /s Assistant United States Attorneys EFTA00090...”
Bobbi C. SternheimGhislaine MaxwellJeffrey Epstein“...oday, we are producing Jencks Act materials relating to , w o was e lo ed by Jeffrey Epstein from The Government anticipates that will testify about, among other things,...”
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EFTA00024791
Court Filing - Letter: 441-1
The document is a letter from the United States Attorney's Office to defense attorneys in the United States v. Ghislaine Maxwell case, informing them that the government intends to refer to Jeffrey Epstein as a co-conspirator at trial. The government has produced co-conspirator statements and will continue to do so as part of its ongoing obligations. The letter is designated as confidential under the Protective Order in the case.
Court Filing - Letter from Prosecutor to Defense Counsel: 442-1
The US Attorney's Office notifies defense counsel that they intend to introduce evidence at trial showing Ghislaine Maxwell's actions to please influential men by providing them with access to women she selected. The evidence includes exhibits and testimony from a witness who worked for Jeffrey Epstein, which the prosecution argues is admissible as direct evidence or under Rule 404(b).
Court Filing - Letter from Prosecutor to Defense Counsel: 385-1
The letter from the US Attorney's office to defense counsel notifies them of evidence and witnesses the government may introduce at trial, including testimony about Jeffrey Epstein's activities and documentary evidence related to the charged crimes. The evidence is deemed admissible as direct evidence or under Rule 404(b). The letter is designated confidential under a protective order.
Court Filing - Letter: 384-1
The document is a letter from the United States Attorney's Office to defense attorneys, informing them that the government intends to refer to Jeffrey Epstein as a co-conspirator of Ghislaine Maxwell at trial. The government has produced co-conspirator statements and will continue to do so as part of its ongoing obligations. The letter is designated as 'confidential' under the Protective Order in the case.
EFTA00020978
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