U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 14, 2021
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:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control number SDNY_GM_02753398.
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_02753398 SDNY_GM_02753398 Photograph Confidential
EFTA00031440
Page 2
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:
Assistant United States Attorneys
EFTA00031441