U.S. Department of Justice
United States Attorney
Southern District of New York
New York, New York 10007
March 29, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
Denver, CO 80203
Bobbi Sternheim, Esq.
LawOffices of Bobbi C. Sternheim
New York, NY 10007
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_02743103 through SDNY_GM_02743292.
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
Desi • nation
SDNY GM 02743103 SDNY GM 02743136 I I
SDNY GM 02743137 SDNY GM 02743142 I I Confidential
SDNY GM 02743143 SDNY GM 02743156 I I
SDNY GM 02743157 SDNY GM 02743188 I I Confidential
EFTA00019084
Page 2
SDNY_GM_02743189 SDNY_GM_02743292
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
EFTA00019085