U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Siltio.1. MoNo Building New York New York 10007 November 20, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C. Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02772262 through SDNY_GM_02775031. 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 information regarding records designated as "confidential" under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. An index of the materials contained in this production is below: EFTA00068429 Page 2 Bates Start Bates End Summary Description Confidential Designation SDNY GM 02772262 SDNY GM 02774104 Records relating to Alfredo Rodriguez Confidential SDNY GM 02774105 SDNY GM 02775026 Records from Insured Aircraft Title Service Confidential SDNY GM 02775027 SDNY GM 02775031 Interlochen records Confidential The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials. Very truly yours, United States Attorney by: s/ Assistant United States Attorneys EFTA00068430