EFTA00098997

U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio!. Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
November 4, 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 (AJN) 
Dear Counsel: 
Pursuant to the Court's November I, 2021 order, we write to provide you with categories 
and exemplars of statements that are admissible as co-conspirator statements under Federal Rule 
of Evidence 801(d)(2)(E). 
Because no attorney can predict the verbatim testimony of a witness, please note that the 
following statements are simply the Government's understanding of the sum and substance of the 
statement. And for that same reason, while we have identified examples of co-conspirator's 
statements that we expect to offer for the truth of the matters asserted therein under Rule 
801(d)(2)(E), we also list certain examples of statements made by co-conspirators that we expect 
will not be offered for the truth of the matters asserted therein. We list these additional examples 
in an abundance of caution, in the event that the witness's statement varies from our expectation 
in a manner that makes some part of the statement admissible for its truth under Rule 801(d)(2)(E). 
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1. Statements made by Epstein to friends and family of Minor Victims 
Epstein had one-on-one conversations with the friends and family of Minor Victims, 
generally on the telephone. For example: 
• 
2. Statements by Epstein to his employees 
Epstein made statements to his employees, including statements that relate to their duties, 
provide background information or history about the conspiracy, or promote efforts to conceal the 
conspiracy. For example: 
• 
In or about 2005, Epstein told an employee witness ("CC-1"), who was identified as a co-
conspirator in the Government's October 11, 2021 letter, that the defendant used to find 
girls for him. 
• 
In or about October 2005, Epstein and an employee ("CC-2"), who was identified as a co-
conspirator in the Government's October II, 2021 letter, told CC-1 to go to his Palm Beach 
house to help someone who was coming to take the computers from Epstein's Palm Beach 
House. 
• 
3. Statements made by CC-2 to the Minor Victims or their families 
CC-2 placed many calls to Minor Victims or their friends and family in order to schedule 
massage appointments. The Government expects several witnesses to testify about receiving those 
calls. For instance: 
• 
4. Statements made by Jeffrey Epstein to the Minor Victims or in their presence 
The Government expects to offer numerous statements made by Jeffrey Epstein to the 
Minor Victims, as well as statements that Epstein made in their presence. Many of these statements 
consist of (a) asking Minor Victims questions about their lives and discussing their future plans, 
or (b) asking them about their sexual preferences, and thus would not be offered for the truth of 
the matters asserted therein. In other instances, however, Epstein made statements about himself 
that would be admissible under Rule 801(d)(2)(E), among other reasons. For example: 
• 
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Very truly yours, 
DAMIAN WILLIAMS 
United States Attorney 
Assistant United States Attorneys 
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