U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Si!lo J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007¶
May 20, 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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim 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_02753432 through SDNY_GM_02753551 and SDNY GM SUPP 00219450 through SDNY_GM_SUPP_00219451.¶
Regarding the materials stamped with control numbers SDNY_GM_02753529 through SDNY_GM_02753551, these folders contain native image files from several devices that correspond with images previously produced to you in PDF format on November 9, 2020. The enclosed spreadsheet indicates which control numbers with “SDNY_GM_SUPP” prefixes correspond with these native “carved” images. The enclosed spreadsheet also details the original file names of the “carved” files that were previously produced to you in their native format, also on November 9, 2020.¶
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 |
|---|---|---|---|
| SDNY GM 02753432 | SDNY GM 02753528 | Interlochen records | Designation Confidential |
| SDNY_GM_02753529 | SDNY_GM_02753529 | Native “carved” images previously produced in PDF format for device NYCO24321 | Confidential |
| SDNY_GM_02753530 | SDNY_GM_02753530 | Native “carved” images previously produced in PDF format for device NYCO24323 | Confidential |
| SDNY GM 02753531 | SDNY GM 02753531 | Native “carved” images previously produced in PDF format for device NYCO24324 | Confidential |
| SDNY_GM_02753532 | SDNY_GM_02753532 | Native “carved” images previously produced in PDF format for device NYCO24326 | Confidential |
| SDNY_GM_02753533 | SDNY_GM_02753533 | Native “carved” images previously produced in PDF format for device NYCO24332 | Confidential |
| SDNY GM 02753534 | SDNY GM 02753534 | Native “carved” images previously produced in PDF format for device NYCO24336 | Confidential |
| SDNY_GM_02753535 | SDNY_GM_02753535 | Native “carved” images previously produced in PDF format for device NYCO24337 | Confidential |
| SDNY_GM_02753536 | SDNY_GM_02753536 | Native “carved” images previously produced in PDF format for device NYCO24340 | Confidential |
| SDNY_GM_02753537 | SDNY_GM_02753537 | Native “carved” images previously produced in PDF format for device NYCO24341 | Confidential |
| SDNY_GM_02753538 | SDNY_GM_02753538 | Native “carved” images previously produced in PDF format for device NYCO24343 | Confidential |
| SDNY_GM_02753539 | SDNY_GM_02753539 | Native “carved” images previously produced in PDF format for device NYCO24348 | Confidential |
| SDNY_GM_02753540 | SDNY_GM_02753540 | Native “carved” images previously produced in PDF format for device NYCO24349 | Confidential |
|---|---|---|---|
| SDNY_GM_02753541 | SDNY_GM_02753541 | Native “carved” images previously produced in PDF format for device NYCO24350 | Confidential |
| SDNY_GM_02753542 | SDNY_GM_02753542 | Native “carved” images previously produced in PDF format for device NYCO24351 | Confidential |
| SDNY_GM_02753543 | SDNY_GM_02753543 | Native “carved” images previously produced in PDF format for device NYCO24363 | Confidential |
| SDNY_GM_02753544 | SDNY_GM_02753544 | Native “carved” images previously produced in PDF format for device NYCO24368 | Confidential |
| SDNY_GM_02753545 | SDNY_GM_02753545 | Native “carved” images previously produced in PDF format for device NYCO24370 | Confidential |
| SDNY_GM_02753546 | SDNY_GM_02753546 | Native “carved” images previously produced in PDF format for device NYCO24372 | Confidential |
| SDNY_GM_02753547 | SDNY_GM_02753547 | Native “carved” images previously produced in PDF format for device NYCO24384 | Confidential |
| SDNY_GM_02753548 | SDNY_GM_02753548 | Native “carved” images previously produced in PDF format for device NYCO24386 | Confidential |
| SDNY_GM_02753549 | SDNY_GM_02753549 | Native “carved” images previously produced in PDF format for device NYCO24388 | Confidential |
| SDNY_GM_02753550 | SDNY_GM_02753550 | Native “carved” images previously produced in PDF format for device NYCO24392 | Confidential |
| SDNY_GM_02753551 | SDNY_GM_02753551 | Native “carved” images previously produced in PDF format for device NYCO27910 | Confidential |
| SDNY _ GM _ SUPP _ 00219450 | SDNY _ GM _ SUPP _ 00219450 | Image from device NYCO24329 | 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,¶
AUDREY STRAUSS United States Attorney¶