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 28, 2021¶
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:¶
Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY_GM_02765768 through SDNY_GM_02767073.¶
Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word “confidential” in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: “SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17.” This marking directly refers to the specific paragraphs of the Protective Order that govern today’s production.¶
An index of the materials contained in this production is below:¶
EFTA00095489¶
Page 2¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
| SDNY_GM_02765768 | SDNY_GM_02765768 | Scanned page of contact book | Confidential |
| SDNY_GM_02765769 | SDNY_GM_02766967 | Materials from Estate of Jeffrey Epstein¹ | Confidential |
| SDNY_GM_02766968 | SDNY_GM_02766974 | Records from the United Kingdom | Confidential |
| SDNY_GM_02766975 | SDNY_GM_02767068 | Scan of 1 bound black address book marked Government Exhibit 52, as referred to in SDNY_GM_02753612 | Confidential |
| SDNY_GM_02767069 | SDNY_GM_02767073 | Scan of 2 stapled handwritten set of documents on yellow legal pad paper, as referred to in SDNY_GM_02753612 | Confidential |
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.¶
Very truly yours,¶
DAMIAN WILLIAMS¶
United States Attorney¶
1 These materials appear to be largely duplicative of materials previously produced to you in discovery.¶
EFTA00095490¶