U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 4, 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. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's November I, 2021 order, we write to provide you with categories and exemplars of statements that are admissible as co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E). Because no attorney can predict the verbatim testimony of a witness, please note that the following statements are simply the Government's understanding of the sum and substance of the statement. A
Summary
U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 4, 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. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's November I, 2021 order, we write to provide you with categories and exemplars of statements that are admissible as co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E). Because no attorney can predict the verbatim testimony of a witness, please note that the following statements are simply the Government's understanding of the sum and substance of the statement. A
Persons Referenced (4)
“...among other reasons. For example: • EFTA00098998 Page 3 Very truly yours, DAMIAN WILLIAMS United States Attorney Assistant United States Attorneys EFTA00098999”
Ghislaine MaxwellJeffrey Epstein“...o testify about receiving those calls. For instance: • 4. Statements made by Jeffrey Epstein to the Minor Victims or in their presence The Government expects to offer nume...”
Tags
Ask AI About This Document
Extracted Text (OCR)
Related Documents (6)
EFTA00032823
Juror ID:
FINAL Juror ID: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA -V- GHISLAINE MAXWELL, Defendant. INSTRUCTION SHEET Dear Juror: X 20 Cr. 330 (MN) JURY QUESTIONNAIRE Please call on November 15, 2021 after 6:00 p.m. for further reporting instructions. Please bring this instruction sheet with you to the courthouse if you are instructed to return. -1- EFTA00077967 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CONSTANCE BAKER MOTLEY JURY ASSEMBLY ROOM 160 SECTION I: JUROR INFORMATION ALL FIELDS IN THIS SECTION MUST BE COMPLETED TO ENSURE YOU RECEIVE YOUR PAYMENT FOR SERVICE Full Name: •Address: Home Phone # Last Fiat M I. Street Address City State Zip Code Aportment/Unit Business Phone I Cell Phone I *NO P.O. BOXES. YOU MUST PROVIDE A RESIDENTIAL ADDRESS FOR MILEAGE REIMBURSEMENT. Social Security # PLEASE SELECT ONE NOTE: ATTENDANCE LETTERS WILL BE MAILED 21 DAYS AFTER SERVICE PRINT ATTENDANCE LET
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).
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
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
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.
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.