This document is a letter from the U.S. Department of Justice to the legal counsel of Ghislaine Maxwell, informing them about potential co-conspirators that the government may refer to during Maxwell's trial.
The letter, dated October 11, 2021, notifies Ghislaine Maxwell's legal team about the government's intention to potentially identify Jeffrey Epstein as a co-conspirator during the trial. It clarifies that the list of co-conspirators is limited to those the Government intends to refer to at trial and doesn't represent a complete list of individuals who may be referenced during the proceedings. The document also mentions the Government has produced co-conspirator statements as per Fed. R. Evid. 801(d)(2)(E) and will continue to provide Jencks Act material.

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EXHIBIT 1 EFTA00025066
U.S. Department of Justice United States Attorney Southern District of New York The Si viol 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 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) Dear Counsel: Pursuant to Judge Nathan's Order of September 3, 2021 (Dkt. No. 335), the Government writes to inform you that it may refer at trial to the following individuals as co-conspirators of the defendant, including for the purpose of Fed. R. Evid. 801(d)(2)(E): • Jeffre E 'stein The Government has produced all co-conspirator statements which it intends to offer at trial pursuant to Fed. R. Evid. 801(d)(2)(E) in the Government's production today or in its previous productions. To the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material. EFTA00025067
Page 2 Please be advised that the above list is limited to the individuals the Government may refer to as co-conspirators at trial. While the Government makes no representations as to whether it views other individuals as potential or actual co-conspirators of the defendant, it does not intend to refer to any other individuals as co-conspirators at trial. The above list is also not intended to reflect a complete list of individuals who may be referenced at trial. That information is contained in the Government's Jencks Act production(s). 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 By: s/ Assistant United States Attorneys Southern District of New York EFTA00025068








