Government Discovery Letter / Disclosure Index - EFTA00017085

Name	Role	Context
Ghislaine Maxwell	Defendant	Subject of the criminal case (20 Cr. 330); records subpoenaed from multiple banks, airlines, and tech companies.
Jeffrey Epstein	Deceased Co-conspirator	Mentioned in financial, travel, email, and estate executor records.
Acting United States Attorney	Sender	Author of the discovery letter (signature redacted).
Silvio J. Mollo	Namesake	Name of the building where the US Attorney's office is located.
[Redacted]	Executors	Epstein Estate Executors mentioned in materials list.
[Redacted]	Associates	Various individuals whose names are redacted in bank and airline records alongside Maxwell and Epstein.

Name	Type	Context
U.S. Department of Justice		Header
United States Attorney Southern District of New York		Prosecuting office
Airline Reporting Corporation		Source of records for Ghislaine Maxwell
Alaska Airlines		Source of records for Ghislaine Maxwell
Amazon		Source of records for Jeffrey Epstein and Ghislaine Maxwell
American Airlines		Source of records for Ghislaine Maxwell
Apple		Source of records for Jeffrey Epstein
AT&T		Source of records
Bank of America		Source of records
Century Link		Source of records
Citibank		Source of records
Delaware Division of Corporations		Records relating to LSJ LLC
LSJ LLC		Subject of Delaware corporation records
Delta Airlines		Source of records for Ghislaine Maxwell
Expedia		Source of records relating to Ghislaine Maxwell
Experian		Source of records relating to Ghislaine Maxwell
Gold Coast Federal Credit Union		Source of records
Google		Source of records for Jeffrey Epstein and Ghislaine Maxwell
Instagram		Source of records for Ghislaine Maxwell
Interlochen		Source of records
MCC		Metropolitan Correctional Center; Request for Emails
Microsoft		Source of records regarding account information for Jeffrey Epstein
MoneyGram		Source of records relating to Ghislaine Maxwell
New York State Department of State		Source of records
Oath Holdings		Source of records for Jeffrey Epstein email accounts
Professional Children's School		Source of records
Charles Schwab		Source of records
Shoppers Travel		Source of records
Southwest		Source of records
Capital One		Source of records
TD Bank		Source of records
PayPal		Source of records for accounts in the name of Jeffrey Epstein and Ghislaine Maxwell
T-Mobile		Source of records
UMB Bank		Source of records (no records notification)
United Airlines		Source of records for Ghislaine Maxwell
UBS Bank		Source of records for accounts related to Ghislaine Maxwell
USAA		Source of records for accounts related to Ghislaine Maxwell
US Virgin Islands Division of Corporations		Records for Laurel Inc, Maple Inc, and Nautilus Inc
Laurel Inc		USVI Corporation
Maple Inc		USVI Corporation
Nautilus Inc		USVI Corporation
Venmo		Source of records for Jeffrey Epstein and Ghislaine Maxwell
Verizon		Source of records
Western Union		Source of records (no accounts found)
TD Ameritrade		Materials for account in the name of Jeffrey Epstein
Granite Reality		Source of materials

Location	Context
New York, New York	US Attorney Office location
US Virgin Islands	Location of corporations (Laurel, Maple, Nautilus)
Delaware	Location of LSJ LLC incorporation

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 5, 2020

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

Dear Counsel:

This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."), and seeks reciprocal discovery.¹

Disclosure by the Government

Based on your request for discovery in this case, enclosed please find copies of the materials listed in the attached index, which materials are stamped with control numbers SDNY_GM_00000001 through SDNY_GM_00012841. If you wish to inspect any of the physical evidence referenced in these materials, including items listed on search inventories, please let us know, and we will make arrangements for you to do so.

The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. Pursuant to those obligations, 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 Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court.

_________________
¹ In addition to information provided herein, please note that this Office periodically posts content on social media platforms including Twitter, Facebook and YouTube. Members of the public may post comments in response to the Office's postings. We do not control these user-generated comments, nor do we monitor or regularly review such comments. You may directly access these social media platforms in the event you believe someone may have posted information relevant to this case.

06.20.2018
EFTA00017085

Page 2

Disclosure by the Defendant

In light of your request for discovery in this case, the Government hereby requests reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of: (1) any books, or copies or portions thereof, which are in the defendant's possession, custody or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental examinations and of scientific tests or experiments made in connection with this case, or copies thereof, which are in the defendant's possession or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the defendant intends to call at trial.

The Government also requests that the defendant disclose prior statements of witnesses he will call to testify. See Fed. R. Crim. P. 26.2; United States v. Nobles, 422 U.S. 225 (1975). We request that such material be provided on the same basis upon which we agree to supply the defendant with 3500 material relating to Government witnesses.

Sentence Reduction for Acceptance of Responsibility

This Office will oppose the additional one-point reduction under the Sentencing Guidelines available for defendants who plead prior to the Government's initiation of trial preparations pursuant to U.S.S.G. § 3E1.1(b), in the event your client has not entered a plea of guilty six weeks prior to trial. We will follow this policy whether or not suppression or other pretrial motions remain outstanding after this date and even if the trial date has not been announced by the Court six weeks in advance of the trial.

Finally, please be advised that pursuant to the policy of the Office concerning plea offers, no plea offer is effective unless and until made in writing and signed by authorized representatives of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not reduced to writing and signed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012).

06.20.2018
EFTA00017086

Page 3

06.20.2018
EFTA00017087

Page 4

06.20.2018
EFTA00017088

Page 5

Very truly yours,
[Redacted]
Acting United States Attorney
by [Redacted]

Enclosure

06.20.2018
EFTA00017089

EFTA00017085.pdf

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