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
March 29, 2021
BY ELECTRONIC MAIL
New York, NY 10022
Denver, CO 80203
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Counsel:
In light of the return of superseding indictment S2 20 Cr. 330 (MN) (the "S2 Indictment"),
the Government writes to provide you with information regarding the individual identified as
Minor Victim-4 in the S2 Indictment. Please note that both this letter is governed by the July 31,
2020 Protective Order in this case. This letter is itself designated as "confidential," because it
includes information regarding records desi nated as "confidential" under the Protective
Order. Minor Victim-4 was born in .
To assist you in identifying portions of the discovery materials that are relevant to the new
allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that
relate to Minor Victim-4, which were already produced to you. Please note that this list, which is
being provided to you as a courtesy, is not exhaustive and does not include every portion of
discovery that is relevant Minor Victim-4.
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Very truly yours,
AUDREY STRAUSS
United States Attorney
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