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

November 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:

In recognition of the Government’s ongoing discovery obligations, today we are producing one hard drive and one CD, which contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY_GM_02742043. The password for the drive is “WO-6291_20201104” and the password for the CD is “USAOsdny1!”. The drive and CD are both 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.

06.20.2018

EFTA00090285

Page 2

<table><thead><tr><th>Bates Start</th><th>Bates End</th><th>Summary Description</th><th>Confidential Designation</th></tr></thead><tbody><tr><td>SDNY_GM_00536837</td><td>SDNY_GM_00869725</td><td>SDNY_PROD015 - PART 01 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_00869726</td><td>SDNY_GM_01216165</td><td>SDNY_PROD015 - PART 02 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_01216166</td><td>SDNY_GM_01546512</td><td>SDNY_PROD015 - PART 03 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_01546513</td><td>SDNY_GM_01964992</td><td>SDNY_PROD015 - PART 04 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_01964993</td><td>SDNY_GM_02292245</td><td>SDNY_PROD015 - PART 05 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_02292246</td><td>SDNY_GM_02678243</td><td>SDNY_PROD015 - PART 06 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_02678244</td><td>SDNY_GM_02735320</td><td>SDNY_PROD015 - PART 07 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_02735321</td><td>SDNY_GM_02742042</td><td>SDNY_PROD016 (Search Warrant Returns)</td><td>Confidential</td></tr><tr><td>SDNY_GM_02742043</td><td>SDNY_GM_02742043</td><td>NYC024318 1B71 (iPhone, images pt. 2)</td><td>Confidential</td></tr></tbody></table>

Please note that the item identified with bates number SDNY_GM_02742043 consists of the final portion of images identified responsive from Subject Device-2, which is an iPhone that law enforcement seized from Jeffrey Epstein at the time of his arrest in 2019. The remainder of the responsive materials from that same device were previously produced to you on November 9, 2020. Due to technical difficulties, we were unable to complete the responsiveness review of images from this device until November 17, 2020.

Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Government produced responsive material from each device to the defense. As noted in the chart, in some instances, the Government determined that there was no responsive material from certain devices and accordingly did not produce any data from those particular devices.

06.20.2018

EFTA00090286

Page 3

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,



Enclosure

06.20.2018