Haddon, Morgan and Foreman, r.0
Laura A. Menninger
H A DD O N 150 East 10th Avenue
MORGAN Denver, Colorado 80203
PH 303.831.7364 EX 303.832.2628
FOREMAN
www.hmflaw.com
LMenninger@hmflaw.com
March 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
1 St. Andrew's Plaza
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Request to view physical evidence, "highly confidential" materials and scenes
Dear Counsel:
I write to formally request an opportunity to (a) view, inspect, and document the physical
evidence seized and held in connection with this case, (b) view and inspect all materials
designated by your office as "Highly Confidential" under the terms of the Protective Order,
and (c) visit, document and inspect any physical scene where you allege illegal conduct
occurred, to include the Epstein properties for which you included photographs in the
Superseding Indictment.
Counsel for Ms. Maxwell and our investigator(s) are available for purposes of reviewing the
physical evidence and Highly Confidential materials on March 17-18, 2021. Given the
volume of materials seized, we anticipate that the evidence view may take more than one eight
(8) hour session to complete and we ask that you plan accordingly. We request that Ms.
Maxwell be present and able to participate in that evidence view.
If you have a log of all evidence seized in connection with this case, we ask that you provide
it to us in advance of the evidence-view so that we may bring the appropriate equipment to
document the items as necessary.
With regard to the scene visits, we are open to discussing dates and times for those to occur
over the next month. Please contact me with your proposal. We will need to make
appropriate travel arrangements.
EFTA00021699
Ms. Comey, Moe and Pomerantz
March 6, 2021
Page 2
If you have any questions, please do not hesitate to contact me.
Respectfully submitted,
Laura A. Menninger 11- 6 7
CC: Counsel of Record via Email
EFTA00021700