Epstein Secrets

instead indicated that it would disclose the identities of Victims 1-3 through its production of Rule 16 discovery, or as part of its production of Jencks Act material closer to trial. EFTA00018578 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 39 Filed 08/10/20 Page 2 of 2 I hereby certify th

tate and before this Court, declare the following is true and correct under penalty of perjury pursuant to 28 U.S.C. § 1746: 1. I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Maxwell in the above-captioned case. 2. I certify pursuant to Local Criminal Rule 16.1 that defense counsel has c

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser 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

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

U.S. Department of Justice United States Attorney Southern District of New York 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

(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