Court Filing: 1:20-cv-00484-DG-KAM

EFTA00016949

EFTA00021685

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 2, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, N Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Mor an and Foreman, P.C. Denver, CO Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 000174967 through SDNY_GM_ 00328863. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes i

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In re: Second Warrant and Order For Prospective and Historical Location Information and Pen Register Information for the Cell hone Assigned Call Number , USAO Reference No. 2018R01618 AMENDED APPLICATION Amended Application for Second Warrant and Order for Cellphone Location and Pen Register Information Mag. The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Second Warrant and Order for prospective and historical location information and pen register information for a cellphone. As grounds for this Amended Application the Government relies on the following facts and authorities. I. Introduction I. lam an Assistant United States Attorney in the U.S. Attorney's Office for the Southern District of New York. This

EFTA00015186

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 March 29, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, 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: In light of the return of superseding indictment S2 20 Cr. 330 (AJN) (the "S2 Indictment"), the Government writes to provide you with information regarding the individual identified as Minor Victim-4 in the S2 Indictment. Please note that both this letter is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes i