EPSTEIN
page 2 / 530 . OCR, unverified
marc.weInsteinfthugheshubbard.com
This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
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From:
Sent: Wednesday, March 31, 2021 1:35 PM
To: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>; ATomback@mclaughlinstern.com
Cc:
Subject: RE: following up
CAUTION: This email was sent by someone outside of the Firm.
Thanks very much— would it be possible to speak slightly later on Monday, perhaps at 3:30 or later? Alternatively, we're
available between 10:30 and 2 p.m. on Monday.
EFTA00026911
--- PAGE 3 ---
From: Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Sent: Wednesday, March 31, 2021 10:58 AM
To:
M=M
:'; ATomback@mclaughlinstern.com
Cc:
Subject: RE: following up
Alison, how about Monday at 2:30pm?
Marc A. Weinstein I Partner
Chair. Valle Cola! Defense
Hughes Hubbard & Reed LLP
One Battery Park Plaza, 17th floor I New York I NY 10004-1482
Office +1 1212) 837-6460 I Cell +1 1646) 537-5750 I Fax +1 (212) 299-6460
marc.weinsteinahugheshubbard.com
this message contains contiountial information and is intended only for trio individual named. If you are not the canted addressee you should not
disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-
mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted. corrupted, lost.
destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this
message. which apse as a result of e-mad transmission. If verification is required please request a hard-copy version.
From:
Sent: Wednesday, March 31, 2021 9:33 AM
To: ATomback@mclaughlinstern.com• Weinstein, Marc A. <marc.weinstein@hugheshubbard.com>
Cc:
Subject: following up
CAUTION: This email was sent by someone outside of the Firm.
Marc and Andy,
Hope you're both doing well. Are you available for a call early next week? We wanted to follow up with you on an aspect
of our previous document requests.
Thanks very much,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00026912
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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.
Bobbi Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
April 12, 2021
Re:
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing certain materials relating to individuals the Government does not
currently intend to call as witnesses at trial in the above-referenced case. Attached please find an
index detailing the materials included in today's production. Please note that both the index and
the enclosed materials are governed by the July 31, 2020 Protective Order in this case. The index
is itself designated as "confidential," because it includes information regarding records
designated as "confidential" under the Protective Order. Please note that many of these
individuals are represented by counsel, as detailed in the attached index. The Government reserves
its right to amend and supplement these disclosures.
This production should not be taken to indicate that the Government believes it has any
obligation to provide all of these materials; rather, we make this production as a courtesy.
Moreover, although the Government presently does not intend to call the individuals listed in the
EFTA00026913
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Page 2
enclosed index, we reserve the right to do so and will notify you should the Government determine
that it intends to call any of these individuals at trial.
Very truly yours,
United States Attorney
by:
s/
Assistant United States Attorneys
EFTA00026914
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