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mith, 19 Cr. 324 (BAH), 2020 WL 5995100, at *19 (D.D.C. Oct. 9, 2020). Here, the Government produced to the defense a witness list, Giglio material, Jencks Act material, and notice pursuant to Federal Rule of Evidence 404(b) by October 11, 2021, or 7 weeks in advance of trial. The Government understands th
he defense to file a motion under Rule 412, or order that any Rule 412 motion be made, at the latest, by October 25, 2021. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) EFTA00065525
im, Esq. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailin
10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00073595
NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailin
10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00090281
NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailin
ed by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys EFTA00090425
NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailin
arking directly refers to the specific paragraphs of the Protective Order that govern today's production. EFTA00094633 Page 2 Very truly yours, DAMIAN WILLIAMS United States Attorney Assistant United States Attorneys EFTA00094634
NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailin
ed by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. Very truly yours, DAMIAN WILLIAMS United States Attorney by: W Assistant United States Attorneys EFTA00095750
Entities connected to both Jencks Act and DAMIAN WILLIAMS

Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATIONSouthern District
LOCATION
Giglio
PERSONthe Southern District
LOCATION
United States
LOCATION
Southern District of New York
ORGANIZATION
Christian Everdell
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Michael Cohen
PERSONFBI
ORGANIZATIONBobbi Stemheim
PERSONCohen & Gresser LLP
ORGANIZATION
Foreman
PERSON
Denver
LOCATIONHaddon
PERSON
Vickers
PERSON