EFTA00018026

EFTA00023532

Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 1 of 3

Case 1:20-cr-00330-AJN Document 309 Filed 07/01/21 Page 1 of 3 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 1, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter to bring to the Court's attention an opinion piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's statements in the Op-Ed were in violation of Local Rule 23.1, which contains provisions relating to extrajudicial public statements by attorneys. Accordingly, for the reasons stated below, the Government respectfully requests t

Court Order: 312

The court orders defense counsel to respond to the government's July 1, 2021 letter motion by July 9, 2021. The order is issued by Judge Alison J. Nathan in the United States District Court for the Southern District of New York. The case involves Ghislaine Maxwell as the defendant.

To: Laura Mennin er tennin e

From: To: Laura Mennin er tennin e mflaw.com>, " " • (USANYS)" Cc: Jeff Pagliuca [email protected]>, "Christian R Everdell - Cohen & Gresser LLP ([email protected])" <[email protected]>, 'BOBBI C STERNHEIM' <[email protected]> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 27 Mar 2021 22:38:06 +0000 Inline-Images: image001.jpg Counsel, Thank you for your email. Below please find our response. If this is acceptable to you, then we will proceed with arranging the logistics of having your client produced to 500 Pearl the week of April 12th and the week April 19th. We will also arrange for the FBI to transport evidence to 500 Pearl for review the week of April 12rh. Physical Evidence • It is not reasonable or feasible to insist that the FBI bring all physical evidence to 500 Pearl Street. That said, we are certainly willing to work with you to ensure that your client can revi

Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential

From: To: ' )" C )" C Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Mon, 15 Mar 2021 23:14:14 +0000 Inline-Images: image001.jpg -notes from call with in red below. From: Sent: Thursday, March 11, 20218:20 PM To:'- (NYPD)' Cc: N. (NY) (FBI) ) `z >; (USANYS) Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Following up on this, we had a call with defense counsel, who asked a number of questions I couldn't answer. Would you please let me know the answers to the below? For the nude/partially nude highly confidential images: • How many highly confidential images are there in total, including both from the discs and from the devices? From the devices approximately 2,100 images/videos (cellebrite is on there) From the discs you previously reviewed them all (3,459), please let us know if you want us to provide to you. Small number of nud

From: Laura Menninge

From: Laura Menninge To: ' Cc: )" USANYS " Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Date: Wed, 28 Apr 2021 16:03:52 +0000 Received. Thank you. -Laura From: Sent: Tuesday, April 27, 2021 9:35 PM To: Laura Menninger Cc: (USANYS) ) < ) ' Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY_GM_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. Best, Southern District of New York I St. Plaza New York NY 10007 From: Sent: Friday, April 23, 2021 1:44 PM To: Laura Menninger < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficien