U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007¶
March 29, 2021¶
BY ELECTRONIC MAIL¶
New York, NY 10007¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)¶
Dear Counsel:¶
In light of the return of superseding indictment S2 20 Cr. 330 (MN) (the “S2 Indictment”), the Government writes to provide you with information regarding the individual identified as Minor Victim-4 in the S2 Indictment. Please note that both this letter is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as “confidential,” because it includes information regarding records desi nated as “confidential” under the Protective Order. Minor Victim-4 was born in .¶
To assist you in identifying portions of the discovery materials that are relevant to the new allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that relate to Minor Victim-4, which were already produced to you. Please note that this list, which is being provided to you as a courtesy, is not exhaustive and does not include every portion of discovery that is relevant Minor Victim-4.¶
Very truly yours,¶