U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen 8: Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C. Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing certain materials relating to an expert the Government currently intends to call as a witness at trial in the above-referenced case. Below please find an index detailing the materials included in today's production. Please note that this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. 3502 Date Description 3502-001 2/1/2021 Interview notes 3502-002 2/1/2021 prior testimony 3502-003 3/3/2021 Interview notes 3502-004 4/9/2021 Interview notes 3502-005 4/21/2021 Interview notes 3502-006 curriculum vitae
Summary
U.S. Department of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen 8: Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C. Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing certain materials relating to an expert the Government currently intends to call as a witness at trial in the above-referenced case. Below please find an index detailing the materials included in today's production. Please note that this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. 3502 Date Description 3502-001 2/1/2021 Interview notes 3502-002 2/1/2021 prior testimony 3502-003 3/3/2021 Interview notes 3502-004 4/9/2021 Interview notes 3502-005 4/21/2021 Interview notes 3502-006 curriculum vitae
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EFTA00020978
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 25, 2020 BY EMAIL 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. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: We write to disclose the attached notes and 302s, which are stam d SDNY_GM_00332929 through SDNY_GM_00332942, from interviews of Please note that the Government is designating the contents of this letter and its enclosures as "Confidential" under the Protective Order in this case. Very truly yours, AUDREY STRAUSS Acting United States Attorney by: s/ Assistant United States Attorneys (212
EFTA00019897
EFTA00031113
EFTA00019896
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 20, 2020 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 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_00328070 through SDNY_GM_00356148. The password for the drive is "USAOsdnyl!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this l
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