Epstein Secrets

r LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C. Dear Counsel: The Silvio I. Motto Building January 10, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) We write in response to your letter of December 28, 20

Pagliuca, Esq. Haddon Mor an and Foreman, P.C. Dear Counsel: The Silvio I. Motto Building January 10, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) We write in response to your letter of December 28, 2020, in which you request a bill of

ernment's letter dated October 28, 2020, with regard to your many requests for information that fall within the scope of the Government's Giglio and Jencks Act obligations, we intend to produce all such material in advance of trial and remain available to confer generally regarding a mutual schedule fo

. Haddon Mor an and Foreman, P.C. Dear Counsel: The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 January 10, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) We write in response to your letter of December 28, 2

ar Counsel: The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 January 10, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) We write in response to your letter of December 28, 2020, in which you request a bill of

ernment's letter dated October 28, 2020, with regard to your many requests for information that fall within the scope of the Government's Giglio and Jencks Act obligations, we intend to produce all such material in advance of trial and remain available to confer generally regarding a mutual schedule fo

ar Counsel: The Silvio J. Mono Building One Saint Andrew's Plaza New York. New York 10007 October 28, 2020 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) We write in response to your letter of O

(S.D.N.Y. Jan. 6, 2010) (declining to order immediate disclosure of Giglio material, because the Government stated it would provide both Giglio and Jencks Act material "shortly before trial"); United States v. Davis, No. 06 Cr. 911 (LBS), 2009 WL 637164, at *14 (S.D.N.Y. March 11, 2009) ("The Second C