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¶
December 16, 2020¶
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 (AJN)¶
Dear Counsel:¶
In recognition of the Government’s ongoing discovery obligations, and due to an error in Bates stamping, today we are reproducing the materials listed in the below index. These discovery materials are now stamped with control numbers SDNY_GM_02742184 through SDNY_GM_02742302.¶
Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. $ ^{1} $ 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:¶
$ ^{1} $ Files in PDF format designated as “confidential” under the protective order have been stamped “confidential.” However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format.¶
EFTA00078383¶
Page 2¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
| SDNY_GM_02742184 | SDNY_GM_02742186 | Reproduction, Deutsche Bank materials relating to Jeffrey Epstein | |
| SDNY_GM_02742187 | SDNY_GM_02742302 | Reproduction, UBS Subpoena Return, 12-15-2020 |
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 or if you wish to arrange a time to review physical items in the FBI’s custody.¶
Very truly yours,¶
AUDREY STRAUSS¶
Acting United States Attorney¶
EFTA00078384¶