STARTS

U.S. Department of Justice

United States Attorney
Southern District of New York

The Si!lo J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007

December 16, 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

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_00274187 through SDNY_GM_0274302.

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.

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Page 2

| Bates Start   | Bates End   | Summary Description             | Confidential<br />Designation    |
|-|-|-|-|
|               |             | UBS Subpoena Return, 12-15-2020 |                                  |

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.

Key information:

*   Audrey Strauss, Acting United States Attorney
*   Signature
*   By: Assistant United States Attorneys (names blocked out)

06.20.2018

EFTA00019423