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# 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

October 20, 2020

# 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:

In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM 00328070 through SDNY_GM_00356148. The password for the drive is The materials are available for pickup at the U.S. Attorney's Office in Manhattan.

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:

# U.S. Department of Justice (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."

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Page 2

# 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_00328070</td><td>SDNY_GM_00328072</td><td>2020.07.02, Aerial Video</td><td></td></tr><tr><td>SDNY GM 00328073</td><td>SDNY_GM_00328092</td><td>FBI Florida Documents</td><td>Confidential</td></tr><tr><td>SDNY_GM_00328093</td><td>SDNY GM 00328289</td><td>FBI NY Documents</td><td></td></tr><tr><td>SDNY GM 00328290</td><td>SDNY GM 00328461</td><td>Misc. Photos</td><td>Confidential</td></tr><tr><td>SDNY_GM_00328462</td><td>SDNY GM 00328667</td><td>PBPD Materials</td><td></td></tr><tr><td>SDNY_GM_00328668</td><td>SDNY GM 00329968</td><td>PBPD Materials</td><td>Confidential</td></tr><tr><td>SDNY_GM_00329969</td><td>SDNY GM 00330052</td><td>PBPD Materials</td><td>Highly Confidential</td></tr><tr><td>SDNY GM 00330053</td><td>SDNY GM 00332355</td><td>PBSA Materials</td><td>Confidential</td></tr><tr><td>SDNY GM 00332356</td><td>SDNY GM 00332436</td><td>Scans of FBI Evidence</td><td></td></tr><tr><td>SDNY GM 00332437</td><td>SDNY GM 00332863</td><td>Scans of FBI Evidence</td><td>Confidential</td></tr><tr><td>SDNY_GM_00332864</td><td>SDNY GM 00332869</td><td>Scans of FBI Evidence</td><td>Highly Confidential</td></tr><tr><td>SDNY_GM_00332870</td><td>SDNY_GM_00332871</td><td>Video from Florida
Investigation</td><td>Highly Confidential</td></tr><tr><td>SDNY_GM_00332872</td><td>SDNY_GM_00332887</td><td>Videos from Florida
Investigation</td><td>Confidential</td></tr><tr><td>SDNY GM 00332888</td><td>SDNY_GM_00332890</td><td>SDFL Materials</td><td>Confidential</td></tr><tr><td>SDNY_GM_00332891</td><td>SDNY_GM_00332891</td><td>SDFL Materials</td><td>Highly Confidential</td></tr><tr><td>SDNY_GM_00332892</td><td>SDNY GM 00332894</td><td>FBI Florida Documents</td><td></td></tr><tr><td>SDNY_GM_00332895</td><td>SDNY_GM_00332928</td><td>FBI FL Documents (included
with 328073-328092)</td><td>Confidential</td></tr><tr><td>SDNY_GM_00332943</td><td>SDNY_GM_00332958</td><td>3-D Blueprints, in PBPD
Materials (included with
328462-328667)</td><td></td></tr><tr><td>SDNY_GM_00332949</td><td>SDNY_GM_00356148</td><td>FBI FL Documents from Discs</td><td>Confidential and
Highly Confidential</td></tr></table>

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

Additionally, as you are aware, the Government has seized and extracted data from multiple electronic devices in connection with search warrants executed at Jeffrey Epstein's properties in New York and the Virgin Islands. The data from those devices has been subject to a privilege review, based on privileges asserted by Jeffrey Epstein's estate. Because the estate has not waived any of those privileges, the Prosecution Team in this case will not have access to any materials from those devices identified as privileged by the taint review team, and the Government will not produce any such privileged material to the defense in this case.

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

Further, it is the Government's current understanding that none of the seized devices belonged to the defendant, Ghislaine Maxwell, and as a result, it is the Government's understanding that the Prosecution Team is not legally permitted to provide you with the full set of non-privileged materials that were extracted from the devices. Instead, the Government anticipates producing only the materials designated responsive to the relevant warrants authorizing the search of these devices. Correspondingly, upon completion of the responsiveness review, the Prosecution Team will only have access to that same set of non-privileged materials deemed responsive to the relevant warrants. The Government expects to produce these responsive, non- privileged materials to you by the November 9, 2020 deadline for completion of discovery.

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

Page 3

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.

Very truly yours,

AUDREY STRAUSS
Acting United States Attorney

by

Assistant United States Attorneys

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