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Correspondence · May 3, 2021

SDNY letter to Maxwell's defense counsel transmitting discovery photographs, May 2021

Prosecutors notify Maxwell's defense attorneys of a confidential discovery production of photographs, referencing the case's protective order.Machine-written summary

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

May 3, 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 (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 StartBates EndSummary DescriptionConfidential
Designation
SDNY GM 02753399SDNY GM 02753431PhotographsConfidential

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,

SDNY letter to Maxwell's defense counsel transmitting discovery photographs, May 2021

Emails and letters

Prosecutors notify Maxwell's defense attorneys of a confidential discovery production of photographs, referencing the case's protective order.

DOJ Epstein Files, Data Set 8 · May 3, 2021

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 May 3, 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 (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 throug…