U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 2, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP New York, N Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Mor an and Foreman, P.C. Denver, CO Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 000174967 through SDNY_GM_ 00328863. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan. 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 Sununary Description Confidential Designation Confidential SDNY_GM_00174967 SDNY_GM_00270985 Deutsche Bank records SDNY_GM_00270986; SDNY_GM_00328070 SDNY_GM_00323934; SDNY_GM_00328863 JPMorgan Chase records Confidential SDNY_GM_00323935 SDNY_GM_00324015 GM Documents ' 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." 0610.2018 EFTA00095317 Page 2 SDNY_GM_00324016 SDNY_GM_00324036 Citibank records for Ghislaine Maxwell SDNY_GM_00324037 SDNY_GM_00325754 UBS records for Angara Trust, Montepelier Trust, Terramar Project, Inc., Max Foundation, Ghislaine Maxwell, Ghislaine Maxwell IRA, & Ellmax, LLC SDNY_GM_00325755 SDNY_GM_00325761 LSJ Scene2Go SDNY_GM_00325762 SDNY_GM_00328069 American Express records for Jeffrey Epstein and Ghislaine Maxwell Confidential The Government is also reproducing to the defendant the files specified in Defense's September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files, the Government offers the following instructions: I. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and selecting "Edit with Notepad" or a similar text-viewing program. 2. Any video file can be opened with VLC, which has been included. 3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional purpose besides assisting in the operation of other (i.e. video) files. 4. Any previously flagged files that are not noted here have been converted to PDFs and/or had their file paths shortened to enable viewing. 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 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 by: Assistant United States Attorneys 0620.2018 EFTA00095318