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emheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Due to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that r
to an error in Bates stamping, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Due to an inadvertent error in Bates stamping in prior productions, which the Government just discovered, today we are reproducing the materials listed in the below index. These items
e Government just discovered, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) D
rmation regarding records designated as "confidential" under the Protective Order. An index of the materials contained in this production is below: Bates Start I Bates End Summary Description Confidential Designation SDNY GM 02753552 SDNY GM 02753588 I B Chains of Custody Logs SDNY GM 02753589
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) D
7, 2021 Letter, in which you request disclosure of "the FBI case file concerning the investigation of Alfredo Rodriguez." The materials within this Bates range constitute the files that the Government referenced in its October 7, 2020 letter to the Court regarding the investigation that led to the pr
MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & resser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mo an and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the material
r Rule 702, we note that his experience and training are described in his curriculum vitae, which was produced to you on September 15, 2021 bearing Bates number 3503-001. EFTA00156627 Page 3 Very truly yours, DAMIAN WILLIAMS United States Attorney by: Assistant United States Attorneys EFTA0015
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
earch, Practice and Policy, and she is a member of the APA Ethics Committee. A copy of Dr. curriculum vitae is being produced to you today bearing Bates number 3502-006.' Dr. is expected to testify, based on her relevant education, training, experience, and research to the following: Individuals wi
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) D
earch, Practice and Policy, and she is a member of the APA Ethics Committee. A copy of Dr. curriculum vitae is being produced to you today bearing Bates number 3502-006.' Dr. is expected to testify, based on her relevant education, training, experience, and research to the following: Individuals wi
IL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim April 23, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Pursuant to Rule 16
ing portions of the discovery materials that are relevant to the new allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that relate to Minor Victim-4, which were already produced to you. Please note that this list, which is being provided to you as a courtesy,
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 Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) D
Entities connected to both Bates and Bobbi Stemheim

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSONSouthern District
LOCATIONLaura Menninger
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Department of Justice
ORGANIZATION
Christian Everdell
PERSONCohen & Gresser LLP
ORGANIZATION
Foreman
PERSONHaddon
PERSONMark Cohen
PERSONFBI
ORGANIZATION
Audrey Strauss
PERSONThe Silvio J. Mollo Building
ORGANIZATION
Julie K. Brown
PERSON
Alison J. Nathan
PERSON
Alfredo Rodriguez
PERSON