EFTA00030992

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 21, 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_000 165541 through SDNY_GM_ 00174966. A reproduction of materials previously produced by the Government on August 12, 2020, which are stamped with control numbers SDNY_GM_00086557 through SDNY_GM_00096055 and SDNY GM 00164920 through SDNY_GM_00165517 is also included. The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Materials stamped with control numbers SDNY_GM_00 166247 through SDNY_GM_00166273, SDNY_GM_00 167093 through SDNY_GM_00167097, SDNY GM 00167911 through SDNY_GM 00167913, SDNY_GM_00 174366 through SDNY_GM_00174369, and SDNY_GM_00 174431 through SDNY_GM_00 174458 have been designated as "highly confidential" because they contain nude, partially nude, or otherwise sexualized images of individuals. Consistent with the Protective Order in this case, the Government is only producing these "highly confidential" materials to defense counsel and is not producing these materials directly to the defendant. 06.20.2018 EFTA00030992 Page 2 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. An index of the materials contained in this production is below: Bates Start Bates End Summary Description Confidential Designation SDNY_ GM_ 00086557; SDNY_GM_00 164920 SDNY_GM_00096055; SDNY_GM_00 165517 Reproduction of Boies Schiller materials Confidential SDNY_GM_00165541 SDNY_GM_00 165557 Emails Confidential SDNY GM_00 165558 SDNY_GM_00 165924 Message pad scans Confidential SDNYIGM_00165925 SDNY_GM_00165981 NYPD computer checks Confidential SDNY_GM_00 165982 SDNY_GM_00 166006 Photos of Journal entries and people Confidential SDNY_GM_00 166007 SDNY_GM_00 166043 Search warrant scans Confidential SDNY_GM_00 166044 SDNY_GM_00 166190 Sentinel search warrant and arrest reports Confidential SDNY_GM_00 166191 SDNY_GM_00 169759 Search warrant photos Confidential SDNY_GM_00 169760 SDNY_GM_00 171456 Ghislaine Maxwell phone data SDNY_GM_00 171457 SDNY_GM_00 172215 Database searches Confidential SDNY_GM_00172216 SDNY_GM_00172217 Recordings from Jeffrey Epstein deposition; February 17, 2010 SDNY_GM_00 172218 SDNY_GM_00 173008 FBI Florida Physical Evidence Confidential SDNY_GM_00173009 SDNY_GM_00173019 Ghislaine Maxwell New Hampshire Residence SDNY GM 00173020 SDNY GM 00173128 Records Confidential SDNY_GM_00 173129 SDNY GM 00173156 Jeffrey Epstein arrest materials and statement Confidential SDNY_GM_00 173157 SDNY_GM_00 173876 Jeffrey Epstein properties SDNY_GM_00173877 SDNY_GM_00173944 Jeffrey Epstein travel and SORNA record,, Confidential SDNY_GM_00 173945 SDNY_GM_00 174213 records Confidential SDNY_GM_00 174214 SDNY_GM_00 174966 Palm Beach Police Department and Florida Materials Confidential This production includes certain materials from the files of the Florida office of the Federal Bureau of Investigation ("FBI"). The Government notes that the remainder of the Florida FBI 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 EFTA00030993 Page 3 files are loaded onto an electronic review platform and will be processed and produced on a rolling basis as part of electronic discovery. Additionally, the Government notes that the physical items referenced in the productions to date can be made available for you to review at the FBI New York office, upon request. Those physical items include numerous hard copies of photographs and discs containing photographs, which were seized during searches of Jeffrey Epstein's residences. As a courtesy, the FBI is in the process of scanning those hard copy photographs and copying the photographs contained on the discs. Once that process is complete, the Government intends to produce electronic copies of any such photographs that do not contain highly confidential images. Any photographs among those physical items identified as highly confidential will be made available for review at the FBI New York office. Finally, the Government wishes to inform you, as a courtesy, that it is in possession of a copy of the FBI's case file regarding the investigation of a former employee of Jeffre E stein's named for obstruction of justice (the "=IM File"). The File is maintained under a different FBI case number from the investigation that led to the charges against your client. The File has no relation to your client and no bearing on the charges in this case. Accordingly, the Government does not intend to produce the File because it is not discoverable in this case. Please do not hesitate to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to review physical items in the FBI's custody. Very truly yours, AUDREY STRAUSS Acting United States Attorney Assistant United States Attorneys 06.20.2018 EFTA00030994