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¶
September 29, 2020¶
BY ELECTRONIC MAIL¶
Christian Everdell, Esq.¶
Mark Cohen, Esq.¶
Cohen & Gresser LLP¶
Laura Menninger, Esq.¶
Jeffrey Pagliuca, Esq.¶
Haddon, Morgan and Foreman, P.C.¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)¶
Dear Counsel:¶
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure (“Fed. R. Crim. P.”). Based on your request for discovery in this case, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_000174967 through SDNY_GM_00328069. The materials are available for pickup at the U.S. Attorney’s Office in Manhattan.¶
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. Such files include in their electronic names the word “Confidential.”¶
06.20.2018¶
EFTA00081924¶
Page 2¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
| SDNY_GM_00174967 | SDNY_GM_00270985 | Deutsche Bank records | Confidential |
| SDNY_GM_00270986 | SDNY_GM_00323934 | JPMorgan Chase records | Confidential |
| SDNY_GM_00323935 | SDNY_GM_00324015 | GM Documents | |
| SDNY_GM_00324016 | SDNY_GM_00324036 | Citibank records for Ghislaine Maxwell | |
| SDNY_GM_00324037 | SDNY_GM_00325754 | UBS records for Angara Trust, Montepelier Trust,Terramar Project,Inc.,Max Foundation,Ghislaine Maxwell,Ghislaine Maxwell IRA,&Ellmax,LLC | |
| SDNY_GM_00325755 | SDNY_GM_00325761 | LSJ Scene2Go | |
| SDNY_GM_00325762 | SDNY_GM_00328069 | American Express records for Jeffrey Epstein and Ghislaine Maxwell | Confidential |
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.¶
06.20.2018¶
EFTA00081925¶