ORANGE

# 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

February 2, 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 Stemheim, Esq.
Law Offices of Bobbi C. Stemheim
33 West 19th Street-4th Fl.
New York, NY 10007

## Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)

## Dear Counsel:

In recognition of the Government's ongoing discovery obligations, today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02742303 through SDNY_GM_02742750. One of the items included in this production is the final report of the Office of Professional Responsibility ("OPR") regarding the resolution of the 2006-2008 criminal investigation of Jeffrey Epstein by the U.S. Attorney's Office for the Southern District of Florida (the "OPR Report"). Although the OPR Report is publicly available and accessible through multiple websites, the Government has elected to produce a copy to you as a courtesy.

In addition, due to an inadvertent error in Bates stamping in the prior production, which the Government just discovered, we are reproducing certain of the materials in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers SDNY _GM_ 00328069.001 through SDNY_GM_ 00328069.794.

EFTA00011267

Page 2

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<br />Designation    |
|-|-|-|-|
| SDNY_GM_02742303   | SDNY_GM_02742395     | AT&T subpoena return, January 28,<br />2021                                            | Confidential                     |
| SDNY_GM_002742396  | SDNY_GM_002742398    | FBI collected item log regarding<br />highly confidential responsive<br />materials    |                                  |
| SDNY_GM_002742399  | SDNY_GM_002742400    | FBI report regarding review of<br />responsive digital evidence                        |                                  |
| SDNY_GM_002742401  | SDNY_CM_002742402    | FBI collected item log regarding 10<br />yearbooks collected from West Palm<br />Beach |                                  |
| SDNY GM 002742403  | SDNY GM 002742750    | Office of Professional Responsibility<br />report dated November 2020                  |                                  |
| SDNYGM00328069.001 | SDNY GM 00328069.794 | REPRODUCTION, JPMorgan Chase<br />materials                                            | 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 or if you wish to arrange a time to review physical items in the FBI's custody.

- Document fragment: signature block from a U.S. Attorney's Office letter.
- Visible text: "Very truly yours,"; "United States Attorney" (name redacted); "by:"; "Assistant United States Attorneys" (names redacted).
- Redactions: five blacked-out name/line blocks (one large block immediately after "by:", three stacked blocks below it, and one block after "Assistant United States Attorneys").
- Context (from surrounding text): pertains to ongoing discovery obligations and production of FBI custody materials.

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.

EFTA00011268