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

October 2, 2020

## BY ELECTRONIC MAIL

Christian Everdell, Esq.

Mark Cohen, Esq.

Cohen & Gresser LLP

New York, NY



Laura Menninger, Esq.

Jeffrey Pagliuca, Esq.

Haddon, Morgan and Foreman, P.C.



Denver, CO

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 copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_000174967 through SDNY_GM_ 00328863. The password for the drive is . 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:

<table border="1"><tr><td>Bates Start</td><td>Bates End</td><td>Summary Description</td><td>Confidential Designation</td></tr><tr><td>SDNY_GM_00174967</td><td>SDNY_GM_00270985</td><td>Deutsche Bank records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00270986; SDNY_GM_00328070</td><td>SDNY_GM_00323934; SDNY_GM_00328863</td><td>JPMorgan Chase records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00323935</td><td>SDNY_GM_00324015</td><td>GM Documents</td><td></td></tr></table>

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.”

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Page 2

<table border="1"><tr><td>SDNY_GM_00324016</td><td>SDNY_GM_00324036</td><td>Citibank records for Ghislaine Maxwell</td><td></td></tr><tr><td>SDNY_GM_00324037</td><td>SDNY_GM_00325754</td><td>UBS records for Angara Trust, Montepelier Trust,Terramar Project,Inc.,Max Foundation,Ghislaine Maxwell,Ghislaine Maxwell IRA,&amp;Ellmax,LLC</td><td></td></tr><tr><td>SDNY_GM_00325755</td><td>SDNY_GM_00325761</td><td>LSJ Scene2Go</td><td></td></tr><tr><td>SDNY_GM_00325762</td><td>SDNY_GM_00328069</td><td>American Express records for Jeffrey Epstein and Ghislaine Maxwell</td><td>Confidential</td></tr></table>

The Government is also reproducing to the defendant the files specified in Defense's September 21, 2020 letter. In order to avoid further difficulties with respect to viewing the files, the Government offers the following instructions:

1. Any .dat, .dvt, and .vol files can be opened and viewed by right-clicking on the file and selecting "Edit with Notepad" or a similar text-viewing program.

2. Any video file can be opened with VLC, which has been included.

3. Accessory files (i.e. .dii, .ami, .cms, etc.) are to be ignored, as they serve no functional purpose besides assisting in the operation of other (i.e. video) files.

4. Any previously flagged files that are not noted here have been converted to PDFs and/or had their file paths shortened to enable viewing.

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

by:



06.20.2018

EFTA00095318