EFTA00028733.pdf

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

May 20, 2021

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_02753432 through SDNY_GM_02753551 and SDNY_GM_SUPP_00219450 through SDNY_GM_SUPP_00219451.

Regarding the materials stamped with control numbers SDNY_GM_02753529 through SDNY_GM_02753551, these folders contain native image files from several devices that correspond with images previously produced to you in PDF format on November 9, 2020. The enclosed spreadsheet indicates which control numbers with "SDNY_GM_SUPP" prefixes correspond with these native "carved" images. The enclosed spreadsheet also details the original file names of the "carved" files that were previously produced to you in their native format, also on November 9, 2020.

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:

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Bates Start | Bates End | Summary Description | Confidential Designation
---|---|---|---
SDNY_GM_02753432 | SDNY_GM_02753528 | Interlochen records | Confidential
SDNY_GM_02753529 | SDNY_GM_02753529 | Native "carved" images previously produced in PDF format for device NYC024321 | Confidential
SDNY_GM_02753530 | SDNY_GM_02753530 | Native "carved" images previously produced in PDF format for device NYC024323 | Confidential
SDNY_GM_02753531 | SDNY_GM_02753531 | Native "carved" images previously produced in PDF format for device NYC024324 | Confidential
SDNY_GM_02753532 | SDNY_GM_02753532 | Native "carved" images previously produced in PDF format for device NYC024326 | Confidential
SDNY_GM_02753533 | SDNY_GM_02753533 | Native "carved" images previously produced in PDF format for device NYC024332 | Confidential
SDNY_GM_02753534 | SDNY_GM_02753534 | Native "carved" images previously produced in PDF format for device NYC024336 | Confidential
SDNY_GM_02753535 | SDNY_GM_02753535 | Native "carved" images previously produced in PDF format for device NYC024337 | Confidential
SDNY_GM_02753536 | SDNY_GM_02753536 | Native "carved" images previously produced in PDF format for device NYC024340 | Confidential
SDNY_GM_02753537 | SDNY_GM_02753537 | Native "carved" images previously produced in PDF format for device NYC024341 | Confidential
SDNY_GM_02753538 | SDNY_GM_02753538 | Native "carved" images previously produced in PDF format for device NYC024343 | Confidential
SDNY_GM_02753539 | SDNY_GM_02753539 | Native "carved" images previously produced in PDF format for device NYC024348 | Confidential

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SDNY_GM_02753540 | SDNY_GM_02753540 | Native "carved" images previously produced in PDF format for device NYC024349 | Confidential
SDNY_GM_02753541 | SDNY_GM_02753541 | Native "carved" images previously produced in PDF format for device NYC024350 | Confidential
SDNY_GM_02753542 | SDNY_GM_02753542 | Native "carved" images previously produced in PDF format for device NYC024351 | Confidential
SDNY_GM_02753543 | SDNY_GM_02753543 | Native "carved" images previously produced in PDF format for device NYC024363 | Confidential
SDNY_GM_02753544 | SDNY_GM_02753544 | Native "carved" images previously produced in PDF format for device NYC024368 | Confidential
SDNY_GM_02753545 | SDNY_GM_02753545 | Native "carved" images previously produced in PDF format for device NYC024370 | Confidential
SDNY_GM_02753546 | SDNY_GM_02753546 | Native "carved" images previously produced in PDF format for device NYC024372 | Confidential
SDNY_GM_02753547 | SDNY_GM_02753547 | Native "carved" images previously produced in PDF format for device NYC024384 | Confidential
SDNY_GM_02753548 | SDNY_GM_02753548 | Native "carved" images previously produced in PDF format for device NYC024386 | Confidential
SDNY_GM_02753549 | SDNY_GM_02753549 | Native "carved" images previously produced in PDF format for device NYC024388 | Confidential
SDNY_GM_02753550 | SDNY_GM_02753550 | Native "carved" images previously produced in PDF format for device NYC024392 | Confidential
SDNY_GM_02753551 | SDNY_GM_02753551 | Native "carved" images previously produced in PDF format for device NYC027910 | Confidential
SDNY_GM_SUPP_00219450 | SDNY_GM_SUPP_00219450 | Image from device NYC024329 | Confidential

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SDNY_GM_SUPP_00219451 | SDNY_GM_SUPP_00219451 | Image from device NYC024366 | Confidential

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.

Very truly yours,

AUDREY STRAUSS
United States Attorney

by:
[REDACTED SIGNATURE BLOCK]
Assistant United States Attorneys

EFTA00028736