U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 28, 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: Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073. 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: EFTA00095489 Page 2 Bates Start Bates End Summary Description Confidential Designation SDNY_GM_02765768 SDNY_GM_02765768 Scanned page of contact book Confidential SDNY_GM_02765769 SDNY_GM_02766967 Materials from Estate of Jeffrey Epstein' Confidential SDNY GM 02766968 SDNY GM 02766974 Records from the United Kingdom Confidential SDNY_GM_02766975 SDNY_GM_02767068 Scan of I bound black address book marked Government Exhibit 52, as referred to in SDNY_GM_02753612 Confidential SDNY_GM_02767069 SDNY_GM_02767073 Scan of 2 stapled handwritten set of documents on yellow legal pad paper, as referred to in SDNY GM 02753612 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, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys ' These materials appear to be largely duplicative of materials previously produced to you in discovery. EFTA00095490