U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Si!lo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 16, 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
Bobbi Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Counsel:
In recognition of the Government's ongoing discovery obligations, today we are producing
the materials listed in the below index. These discovery materials are stamped with control
numbers SDNY_GM_00274187 through SDNY_GM_0274302.
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:
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.
06.20.2018
EFTA00019422
Page 2
Bates Start Bates End Summary Description Confidential
Designation
UBS Subpoena Return, 12-15-2020
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
b
cktant United States Attorneys
06.20.2018
EFTA00019423