U.S. Department of Justice
United States Attorney
Southern District ofNew York
The Si!lo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
August 5, 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_02753644 through SDNY_GM_02753697.
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. Recently, 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.
EFTA00027301
Page 2
An index of the materials contained in this production is below:
Bates Start Bates End Summary Description Confidential
Designation
Files Recovered from Discs Confidential
Seized from Epstein NY
SDNY GM 02753644 SDNY GM 02753684 Residence
De-Designated Images from Confidential
SDNY GM_02753685 SDNY GM_02753692 Epstein's Electronic Devices
SDNY_GM_02753693 SDNY GM_02753695 Missouri Records Confidential
SDNY_GM_02753696 SDNY GM_02753696 JPMorgan Chase Return Confidential
SDNY GM 02753697 SDNY GM 02753697 Oxford Letter, 11-07-1995 Confidential
Please note that the files recovered from discs seized from Jeffrey Epstein's New York
residence and the De-Designated Images from Epstein's Electronic Devices are being produced to
you with html files that contain thumbnails of each image and any recovered metadata next to each
thumbnail. In order to view the full size image from a particular row in the html file, click on the
thumbnail, which will automatically open up the full size image from within the folder structure
maintained in the folder entitled "Files." Use of these html files does not require Internet access,
but does require that the file structure within the folder entitled "Files" remain unchanged.
Additionally, certain of the files that were recovered from the discs seized from Epstein's New
York residence are not viewable on the FBI's system. In the interest of completeness, however,
we are producing to you every file that was recovered from those discs, including those that are
not openable or viewable.
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,
United States Attome
by
Assistant United States Attorneys
EFTA00027302