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 18, 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:¶
Due to an inadvertent error in Bates stamping in prior productions, which the Government just discovered, today we are reproducing the materials listed in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers SDNY_GM_02742184 through SDNY_GM_02742302.¶
An index of the replacement materials contained in this production is below:¶
| 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 |
EFTA00078387¶
Page 2¶
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¶
EFTA00078388¶