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Correspondence · April 14, 2021

SDNY discovery production letter to Maxwell defense counsel, April 2021

A letter from the U.S. Attorney's Office transmitting one confidential photograph to Ghislaine Maxwell's defense counsel as discovery, per the 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

April 14, 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 number SDNY_GM_02753398.

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
SDNY_GM_02753398SDNY_GM_02753398PhotographDesignation
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,