EFTA00015186

U.S. Department of Justice United States Attorney Southern District of New York The Silvio .1. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 7, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02762507 through SDNY_GM_02763017. 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. EFTA00015186 Page 2 An index of the materials contained in this production is below: Bates Start Bates End Summary Description Confidential Designation SDNY GM_02762507 SDNY GM 02762567 SDFL files' SDNY_GM_02762568 SDNY_GM_02762569 JPMC documentsi SDNY GM 02762570 SDNY GM 02762637 Database files (Ghislaine Maxwell) SDNY_GM_02762638 SDNY_GM_02762663 Database files (Jeffrey Epstein) SDNY_GM_02762664 SDNY_GM_02762775 FAA records Confidential SDNY GM 02762776 SDNY GM 02762776 FedEx records Confidential SDNY_GM_02762777 SDNY_GM_02762831 Miscellaneous SDNY_GM_02762832 SDNY_GM_02763004 Miscellaneous Confidential SDNY GM 02763005 SDNY GM 02763007 Photographs SDNY_GM_02763008 SDNY_GM_02763016 Photographs Confidential SDNY_GM_02763017 SDNY_GM_02763017 Photos of Palm Beach House 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: s/ ' • tes Attorneys ' We are unable to view these files, as they are either corrupt or we do not have the requisite software to view them, but we are producing these files to you in an abundance of caution. We are unable to view the JPMC files, which we understand to be from FBI in Florida. The two files are password protected, but we are producing these files to you in an abundance of caution. EFTA00015187