COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com August 27, 2020 BY EMAIL , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Ms. Comey, Ms. Moe, and Ms. Pomerantz: 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write to alert you to several problems with the discovery productions that have been provided to Ms. Maxwell in the MDC, and to register our dissatisfaction with the manner in which that discovery was provided. First, according to Judge Nathan's scheduling order (Dkt. 25), the deadline for completing production of initial non-electronic discovery was Friday, August 21, 2020. Ms. Maxwell did not receive her copy of the third and final production in this phase of discovery until the late morning on Tuesday, August 25, several days after the deadline imp