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
February 2, 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:
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_02742303 through SDNY_GM_02742750. One of the items included in
this production is the final report of the Office of Professional Responsibility ("OPR") regarding
the resolution of the 2006-2008 criminal investigation of Jeffrey Epstein by the U.S. Attorney's
Office for the Southern District of Florida (the "OPR Report"). Although the OPR Report is
publicly available and accessible through multiple websites, the Government has elected to
produce a copy to you as a courtesy.
In addition, due to an inadvertent error in Bates stamping in the prior production, which
the Government just discovered, we are reproducing certain of the materials in the below index.
These items were originally produced with incorrect Bates numbers that resulted in overlaps.
These errors have now been corrected. These discovery materials are now stamped with the correct
control numbers SDNY_GM_00328069.001 through SDNY_GM_00328069.794.
EFTA00011267
Page 2
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
AT&T subpoena return, January 28,
SDNY_GM_02742303 SDNY_GM_02742395
2021 Confidential
FBI collected item log regarding
highly confidential responsive
SDNY_GM_002742396 SDNY_GM_002742398 materials
FBI report regarding review of
SDNY_GM_002742399 SDNY_GM_002742400 responsive digital evidence
FBI collected item log regarding 10
yearbooks collected from West Palm
SDNY_GM_002742401 SDNY_CM_002742402 Beach
Office of Professional Responsibility
SDNY GM 002742403 SDNY GM 002742750 report dated November 2020
REPRODUCTION, JPMorgan Chase
SDNYGM00328069.001 SDNY GM 00328069.794 materials Confidential
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
United States Attorney
b
Assistant United States Attorneys
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.
EFTA00011268