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 13, 2021¶
BY ELECTRONIC MAIL¶
Christian Everdell, 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:¶
You requested a copy of the spreadsheets on the hard drives you have reviewed at the FBI office in Denver. Those spreadsheets are embedded with hyperlinks to the images on the hard drives. The Government is not able to provide you with copies of the versions of the spreadsheets on the hard drives because those spreadsheets are embedded with photographs depicting, among other things, child exploitation materials. However, the FBI has prepared a version of the spreadsheets you requested without the embedded photographs, which we are producing to you today, as listed in the below index. These materials are stamped with control numbers SDNY_GM_02765031 through SDNY_GM_02765061.¶
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,¶
EFTA00098129¶
Page 2¶
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:¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
| SDNY GM 02765031 | SDNY GM 02765061 | Spreadsheets | Confidential |
Very truly yours,¶
DAMIAN WILLIAMS¶
United States Attorney¶
EFTA00098130¶