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
November 9, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Mo an and Foreman, P.C.
Bobbi Sternheim, 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 materials are
stamped with control numbers SDNY_GM_02767074 through SDNY_GM_02771980.
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. 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.
An index of the materials contained in this production is below:
EFTA00010017
Page 2
Bates Start Bates End Summary Description Confidential Designation
SDNY GM 02767074 SDNY GM 02771980 Business Records from SDFL Files, Confidential
Although the Government believes that all of these materials are also located in the Florida
FBI file and were previously produced to from that file in the fall of 2020, out of an abundance of
caution, the Government is producing these records to you in the form in which they were stored
in the files maintained by the U.S. Attorney's Office for the Southern District of Florida. 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,
DAMIAN WILLIAMS
United States Attorney
These materials appear to be largely duplicative of materials previously produced to you in
discovery.
EFTA00010018