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

August 13, 2020

## 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

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

Dear Counsel:

This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."). Based on your request for discovery in this case, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_ 00012842 through SDNY_GM_ 00165540. The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Additionally, to aid in the preparation of the defense, the Government hereby provides notice of the month and year in which the minor victims listed in the Indictment in the above-referenced casewere born. Minor Victim1 was born in August of 1980. Minor Victim-2 was born in July of 1979. Minor Victim-3 was born in March of 1977.

Please note that both this letter and enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes witness-identifying information and information regarding records designated as "confidential" under the Protective Order.

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."

06.20.2018

EFTA00029632

Page 2

An index of the materials contained in this production is below:

<table><tr><th>Bates Start</th><th>Bates End</th><th>Summary Description</th><th>Confidential
Designation </th></tr><tr><td>SDNY_GM_00012842</td><td>SDNY_GM_00020407</td><td>First Bank of Puerto Rico Records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00020408</td><td>SDNY_GM_00028286</td><td>UBS Financial Records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00028287</td><td>SDNY_GM_00029786</td><td>Wells Fargo Records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00029787</td><td>SDNY_GM_00037176</td><td>Fifth Third Bank records</td><td>Confidential</td></tr><tr><td>SDNY GM 00037177</td><td>SDNY GM 00065957</td><td>Deutsche Bank Records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00065958</td><td>SDNY_GM_00078659</td><td>JPMorgan Chase Bank records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00078660</td><td>SDNY_GM_00165521</td><td>Boies Schiller records</td><td>Confidential</td></tr><tr><td>SDNY_GM_00165522</td><td>SDNY_GM_00165540</td><td>Experian records</td><td></td></tr></table>

Please do not hesitate to reach out if you have any difficulty accessing these materials.

- "Very truly yours,"
- [Name redacted], Acting United States Attorney
- Large black redaction block (signature area) preceded by "by:"
- "Assistant United States Attorneys"
- Smaller black redaction block (names/information redacted)

06.20.2018

EFTA00029633