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 (AJN)

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 case were born. Minor Victim- 1 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.

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

1 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

EFTA00030714

Page 2

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

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,

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

AUDREY STRAUSS
Acting United States Attorney

by:

Assistant United States Attorneys

06.20.2018

EFTA00030715