Datasets:
title: DOJ Epstein Files, Data Set 9 (EFTA00090463)
source: DOJ Epstein Files, Data Set 9
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date: '2026-01-01'
category: DOJ Data Set
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EXHIBIT A
EFTA00090463
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.
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 as a witness at trial. Today, we are producing Jencks Act materials relating to who was employed by Jeffrey Epstein from The Government anticipates that will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls.
EFTA00090464
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
EFTA00090465