EFTA00029632

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 August 13, 2020 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 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."). Based on your request for discovery in this case, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_ GM_ 00012842 through SDNY_GM_ 00165540. The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Additionally, to aid in the preparation of the defense, the Government hereby provides notice of the month and year in which the minor victims listed in the Indictment in the above-referenced case were born. Minor Victim- 1 was born in August of 1980. Minor Victim-2 was born in July of 1979. Minor Victim-3 was born in March of 1977. Please note that both this letter and enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes witness-identifying information and information regarding records designated as "confidential" under the Protective Order. Files in PDF format designated as "confidential" under the protective order have been stamped "confidential." However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. Such files include in their electronic names the word "Confidential." 06.20.2018 EFTA00029632 Page 2 An index of the materials contained in this production is below: Bates Start Bates End Summary Description Confidential Designation SDNY_GM_000 12842 SDNY_GM_00020407 First Bank of Puerto Rico Records Confidential SDNY_GM_00020408 SDNY_GM_00028286 UBS Financial Records Confidential SDNY_GM_00028287 SDNY_GM_00029786 Wells Fargo Records Confidential SDNY_GM_00029787 SDNY_GM_00037176 Fifth Third Bank records Confidential SDNY GM 00037177 SDNY GM 00065957 Deutsche Bank Records Confidential SDNY_GM_00065958 SDNY_GM_00078659 JPMorgan Chase Bank records Confidential SDNY_GM_00078660 SDNY_GM_00 165521 Boies Schiller records Confidential SDNY_GM_00 165522 SDNY_GM_00 165540 Experian records Please do not hesitate to reach out if you have any difficulty accessing these materials. Very truly yours, AUDREY STRAUSS Acting United States Attorney by Assistant United States Attorneys 06.20.2018 EFTA00029633