U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Silvio .1. Mollo Building One Saint Andrew’s Plaza New York, New York 10007¶
October 7, 2021¶
BY ELECTRONIC MAIL¶
Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP¶
Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C.¶
Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim¶
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_02762507 through SDNY_GM_02763017.¶
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.¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
|---|---|---|---|
| SDNY GM_02762507 | SDNY GM 02762567 | SDFL files’ | |
| SDNY_GM_02762568 | SDNY_GM_02762569 | JPMC documentsi | |
| SDNY GM 02762570 | SDNY GM 02762637 | Database files (Ghislaine Maxwell) | |
| SDNY_GM_02762638 | SDNY_GM_02762663 | Database files (Jeffrey Epstein) | |
| SDNY_GM_02762664 | SDNY_GM_02762775 | FAA records | Confidential |
| SDNY GM 02762776 | SDNY GM 02762776 | FedEx records | Confidential |
| SDNY_GM_02762777 | SDNY_GM_02762831 | Miscellaneous | |
| SDNY_GM_02762832 | SDNY_GM_02763004 | Miscellaneous | Confidential |
| SDNY GM 02763005 | SDNY GM 02763007 | Photographs | |
| SDNY_GM_02763008 | SDNY_GM_02763016 | Photographs | Confidential |
| SDNY_GM_02763017 | SDNY_GM_02763017 | Photos of Palm Beach House |
An index of the materials contained in this production is below:¶
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¶
' We are unable to view these files, as they are either corrupt or we do not have the requisite software to view them, but we are producing these files to you in an abundance of caution.¶
We are unable to view the JPMC files, which we understand to be from FBI in Florida. The two files are password protected, but we are producing these files to you in an abundance of caution.¶