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efta-efta00098129DOJ Data Set 9Other

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Siltio.1. Moll° Building Otte Saint Andrew's Plaza New York New York 10007 October 13, 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 Stemheim, 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: You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hand drives. The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation m

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00098129
Pages
2
Persons
4
Integrity

Summary

U.S. Department of Justice United States Attorney Southern District of New York The Siltio.1. Moll° Building Otte Saint Andrew's Plaza New York New York 10007 October 13, 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 Stemheim, 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: You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hand drives. The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation m

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
U.S. Department of Justice United States Attorney Southern District of New York The Siltio.1. Moll° Building Otte Saint Andrew's Plaza New York New York 10007 October 13, 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 Stemheim, 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: You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hand drives. The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation materials. However, the FBI has prepared a version of the spreadsheets you requested without the embedded photographs, which we are producing to you today, as listed in the below index. These materials are stamped with control numbers SDNY GM 02765031 through SDNY GM 02765061. 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, EFTA00098129 Page 2 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: Bates Start Bates End Summary Description Confidential Designation SDNY GM 02765031 SDNY GM 02765061 Spreadsheets Confidential Very truly yours, DAMIAN WILLIAMS United States Attorney / 1 b s/ EFTA00098130

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Related Documents (6)

DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. EFTA00090929 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under

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Dept. of JusticeOtherUnknown

Stipulation Agreement: doj-ogr-00015170

This document is a stipulation agreement between the United States Attorney's Office and Ghislaine Maxwell's defense team, agreeing to admit a stipulation as evidence at trial, marked as Government Exhibit 1010, dated December 17, 2021.

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DOJ Data Set 8CorrespondenceUnknown

EFTA00031113

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA STIPULATION GHISLAINE MAXWELL, Defendant. x S2 20 CR 330 (AJN) IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: 1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. EFTA00099019 2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006 may be received in evidence at trial. Dated: November 2021 New York, New York DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: Ass

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Dept. of JusticeOtherUnknown

Stipulation Agreement: doj-ogr-00015165

The document is a stipulation agreement between the prosecution and defense in the case against Ghislaine Maxwell, agreeing to admit Defense Exhibit A1 into evidence at trial, dated December 17, 2021.

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Court UnsealedOtherUnknown

Stipulation: 1009

This document is a stipulation between the United States Attorney's Office and Ghislaine Maxwell's defense team, agreeing to admit a specific stipulation as evidence at trial, marked as Government Exhibit 1009. The stipulation is dated December 10, 2021, and signed by representatives from both parties. It relates to the trial preparation and evidence submission in the case against Ghislaine Maxwell.

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