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 4, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02762476 through SDNY_GM_02762506. 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. Recently, 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, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. EFTA00087606 Page 2 An index of the materials contained in this production is below: Bates Start Bates End Summary Description Confidential Designation SDNY_GM_02762476 SDNY GM 02762476 Video Confidential SDNY GM 02762477 SDNY GM 02762477 Photo of 44 Kinnerton Street, London SW I ._ i 8ES United Kingdom SDNY_GM_02762478 SDNY_GM_02762482 = Deposition Documentsl Confidential SDNY_GM_02762483 SDNY_GM_02762483 JPMorgan Chase records Confidential SDNY GM 02762484 SDNY GM 02762485 Maps of Palm Beach area SDNY_GM_02762486 SDNY_GM_02762487 Palm Beach School District records Confidential SDNY_GM_02762488 SDNY_GM_02762491 Jeffrey Epstein travel records SDNY GM 02762492 SDNY GM 02762500 Ghislaine Maxwell travel records SDNY_GM_02762501 SDNY_GM_02762501 travel records Confidential SDNY_GM_02762502 SDNY_GM_02762506 FBI NY documents The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials. Very truly yours, AUDREY STRAUSS United States Attorney by: s/ MN. • • rates Attorneys The Government received some of the files in a format we are not able to open but we are producing the .ecl files to you in an abundance of caution. EFTA00087607