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¶
April 9, 2021¶
BY ELECTRONIC MAIL¶
Christian Everdell, Esq.¶
Mark Cohen, Esq.¶
Cohen & Gresser LLP¶
Laura Menninger, Esq.¶
Jeffrey Pagliuca, Esq.¶
Haddon, Morgan and Foreman, P.C.¶
Bobbi Sternheim, Esq.¶
Law Offices of Bobbi C. Sternheim¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)¶
Dear Counsel:¶
Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02743293 through SDNY_GM_02753397.¶
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. An index of the materials contained in this production is below:¶
| Bates Start | Bates End | Summary Description | Confidential Designation |
| SDNY_GM_02743293 | SDNY_GM_02753127 | Records from American Express | |
| SDNY_GM_02753128 | SDNY_GM_02753138 | Records from T-Mobile | |
| SDNY_GM_02753139 | SDNY_GM_02753143 | Customs and Border Patrol Records | Confidential |
EFTA00105698¶
Page 2¶
| SDNY_GM_02753144 | SDNY_GM_02753291 | Materials from FBI Florida relating to Alfredo Rodriguez investigation¹ | |
| SDNY_GM_02753292 | SDNY_GM_02753317 | FBI Florida document | Confidential |
| SDNY_GM_02753318 | SDNY_GM_02753395 | Palm Beach Police Department records | Confidential |
| SDNY_GM_02753396 | SDNY_GM_02753397 | Palm Beach Police Department video surveillance footage |
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,¶
AUDREY STRAUSS¶
United States Attorney¶
1 We are in receipt of your April 7, 2021 Letter, in which you request disclosure of “the FBI case file concerning the investigation of Alfredo Rodriguez.” The materials within this Bates range constitute the files that the Government referenced in its October 7, 2020 letter to the Court regarding the investigation that led to the prosecution in United States v. Alfredo Rodriguez, 10 Cr. 80015 (KAM). This production should not be taken to indicate that the Government believes it has any obligation, under Rule 16 or otherwise, to produce these materials; rather, we make this production as a courtesy.¶
EFTA00105699¶