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 13, 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. Gldilaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: You requested a copy of the spreadsheets which contain links to the photo files contained on the hard drives you have reviewed at the FBI office in Denver. The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation materials. However, the FBI has prepared a version of the spreadsheets you requested without the embedded photographs, which we are producing to you today, as listed in the below index. These materials are stamped with control numbers SDNY_GM_02765030 through SDNY_GM_XXXX. 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, EFTA00098127 Page 2 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: Bates Start Bates End Summary Description Confidential Designation SDNY_GM_0276503 I SDNY_GM_0276XXXX FBI Spreadsheets Confidential Very truly yours, DAMIAN WILLIAMS United States Attorney by: s/ Assistant United States Attorneys (212) 637-2324 EFTA00098128