U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Silvio .1. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
October 28, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
New YorlNY
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Mo an and Foreman, P.C.
Denver, CO
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
New York, NY
Re: Lnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Counsel:
Today we are producing the materials listed in the below index. These materials are
stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02766974.
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.
An index of the materials contained in this production is below:
EFTA00024791
Page 2
Bates Start Bates End Summary Description Confidential Designation
SDNY_GM_02765768 SDNY_GM_02765768 Scanned page of contact book Confidential
SDNY_GM_02765769 SDNY_GM_02766967 Materials from Estate of Jeffrey Epstein' Confidential
SDNY_GM_02766968 SDNY_GM_02766974 Records from the United Kingdom 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.
Very truly yours,
DAMIAN WILLIAMS
United States Attorney
by: s/
Assistant United States Attorneys
' These materials appear to be largely duplicative of materials previously produced to you in
discovery.
EFTA00024792