U.S. Department of Justiee
United States Attorney
Southern District ofNew York
The Si!lo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
May 3, 2021
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
800 Third Avenue
New York, NY 10022
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon, Morgan and Foreman, P.C.
150 East Tenth Avenue
Denver, CO 80203
Bobbi Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
33 West 19th Street-4th Fl.
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Counsel:
Today we are producing the materials listed in the below index. These discovery materials
are stamped with control numbers SDNY_GM_02753399 through SDNY_GM_02753431.
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
Designation
SDNY_GM_02753399 SDNY GM 02753431 Photographs Confidential
EFTA00024868
Page 2
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
Assistant United States Attorneys
EFTA00024869