# 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 26, 2021

# U.S. Department of Justice (cont.)

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 discovery materials are stamped with control numbers SDNY_GM_02742751 through SDNY_GM_02742962.

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:

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.

EFTA00022655

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# U.S. Department of Justice (cont.)

<table><tr><th>Bates Start</th><th>Bates End</th><th>Summary Description</th><th>Confidential
Designation</th></tr><tr><td>SDNY_GM_02742751</td><td>SDNY_GM_02742752</td><td>American Express records</td><td></td></tr><tr><td>SDNY_GM_02742753</td><td>SDNY GM 02742754</td><td>Amanda Kramer emails</td><td>Confidential</td></tr><tr><td>SDNY_GM_02742755</td><td>SDNY GM 02742762</td><td>A. Kramer emails</td><td></td></tr><tr><td>SDNY GM 02742763</td><td>SDNY_GM_02742877</td><td>Emails between Serene Nakano and
A. Marie Villafana</td><td></td></tr><tr><td>SDNY_GM_02742878</td><td>SDNY GM 02742886</td><td>A. Kramer February 2016 meeting
notes</td><td>Confidential</td></tr><tr><td>SDNY_GM_02742887</td><td>SDNY_GM_02742892</td><td>Notes of February 11, 2021 Call with
A. Kramer</td><td></td></tr><tr><td>SDNY_GM_02742893</td><td>SDNY GM 02742894</td><td>Notes from the U.S. Attorney's
Office for the Southern District of
Florida</td><td></td></tr><tr><td>SDNY GM 02742895</td><td>SDNY GM 02742962</td><td>Flight log provided to A. Kramer at
February 2016 meeting</td><td>Confidential</td></tr></table>

# U.S. Department of Justice (cont.)

Among the materials contained in this production is an excerpt of a flight log that former Assistant United States Attorney received during a February 29, 2016 meeting with attorneys representing (the "February 2016 meeting"). At the February 2016 meeting, AUSA received copies of Jeffrey Epstein's black book, excerpts of flight records, and certain Palm Beach Police Department reports. Epstein's black book and the Palm Beach Police Department reports were previously produced to you on August 21, 2020, and can be found at SDNY_GM_00174731-SDNY_GM_00174827 and SDNY_GM_00174880- SDNY_GM_00174966 respectively. Today we are producing to you the version of the flight records AUSA Kramer received at the February 2016 meeting, which includes a subset of logs previously produced to you on August 5, 2020 (see SDNY_GM_00005532- SDNY_GM_00005676) as well as two additional pages that were not previously produced to you in discovery, see SDNY_GM_02742935 and SDNY_GM_02742937.

# U.S. Department of Justice (cont.)

Additionally, in recognition of the Government's obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, we are disclosing the information below. This disclosure should not be taken to indicate that the Government believes the enclosed information constitutes Brady material. Rather, we make this disclosure in an abundance of caution. Specifically, the Government discloses the following:

The witness identified as witness "M" in a 2007 ex parte declaration, which you attached as Exhibit B to the Defense Pretrial Motion Number 10 for Bill of Particulars and Pre-Trial Disclosures in this case, is On or about November 14, 2006, was interviewed by the Federal Bureau of Investigation. The notes from that interview contain the following line on page 12: "rumor is that JE is gay," apparently referring to a rumor regarding Jeffrey Epstein's sexual orientation.

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

EFTA00022656

# U.S. Department of Justice (cont.)

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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.

Very truly yours,

AUDREY STRAUSS
United States Attorney

by:

EFTA00022657