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Document 385-1

AI Analysis

Summary: 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.
Significance: This document is potentially important as it reveals the prosecution's strategy and evidence in the case against Ghislaine Maxwell, including the witnesses they intend to call and the evidence they plan to introduce.
Key Topics: Evidence to be introduced at trial Witness testimony Admissibility of evidence under Rule 404(b)
Key People:
  • Ghislaine Maxwell - Defendant in the case United States v. Ghislaine Maxwell
  • Jeffrey Epstein - Individual associated with the charged crimes
  • Alison Moe - Assistant United States Attorney
  • Lara Pomerantz - Assistant United States Attorney
  • Andrew Rohrbach - Assistant United States Attorney
  • Damian Williams - United States Attorney
  • Christian Everdell - Defense Counsel
  • Laura Menninger - Defense Counsel
  • Jeffrey Pagliuca - Defense Counsel
  • Bobbi Sternheim - Defense Counsel
Document Type
Exhibit
Date
10/29/21
Pages
3
Folder
IMAGES002

Full Text

Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 1 of 3 EXHIBIT A DOJ-OGR-00005622 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 2 of 3 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 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 (AJN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In particular, the Government may offer certain exhibits at trial that demonstrate that, [REDACTED] We are producing these proposed exhibits today, marked with the following exhibit numbers: GX 401 through 404, GX 409 through 410, and GX 413. In addition, please be advised that the Government may call [REDACTED] as a witness at trial. Today, we are producing Jencks Act materials relating to [REDACTED], who was employed by Jeffrey Epstein from [REDACTED]. The Government anticipates that [REDACTED] will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that [REDACTED] will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls. DOJ-OGR-00005623 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 3 of 3 Page 2 This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of accident with respect to the charges in the above-referenced case. Because this evidence is admissible as direct evidence, the Government is not planning to affirmatively move in limine to seek its admission. Please note that this letter and the information contained herein is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential" under the Protective Order. Very truly yours, DAMIAN WILLIAMS United States Attorney by: /s Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys (212) 637-2324 DOJ-OGR-00005624

Individual Pages

Page 1 - DOJ-OGR-00005622
Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 1 of 3 EXHIBIT A DOJ-OGR-00005622
Page 2 of 3 - DOJ-OGR-00005623
Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 2 of 3 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 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 (AJN) Dear Counsel: We write to notify you that the Government may seek to introduce certain evidence at trial. In particular, the Government may offer certain exhibits at trial that demonstrate that, [REDACTED] We are producing these proposed exhibits today, marked with the following exhibit numbers: GX 401 through 404, GX 409 through 410, and GX 413. In addition, please be advised that the Government may call [REDACTED] as a witness at trial. Today, we are producing Jencks Act materials relating to [REDACTED], who was employed by Jeffrey Epstein from [REDACTED]. The Government anticipates that [REDACTED] will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that [REDACTED] will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls. DOJ-OGR-00005623
Page 3 of 3 - DOJ-OGR-00005624
Case 1:20-cr-00330-PAE Document 385-1 Filed 10/29/21 Page 3 of 3 Page 2 This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of accident with respect to the charges in the above-referenced case. Because this evidence is admissible as direct evidence, the Government is not planning to affirmatively move in limine to seek its admission. Please note that this letter and the information contained herein is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential" under the Protective Order. Very truly yours, DAMIAN WILLIAMS United States Attorney by: /s Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys (212) 637-2324 DOJ-OGR-00005624