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Case 1:20-cr-00330-AJN Document 69 Filed 11/06/20 Page 1 of 4
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

November 6, 2020

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/9/20

BY ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007

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

Dear Judge Nathan:

The Government respectfully submits this letter to request an extension of the deadline for the production of a subset of the electronic discovery in the above-referenced case from November 9, 2020 to November 23, 2020. This extension is necessary solely to allow adequate time for an outside vendor to finalize the preparation of documents extracted from electronic devices seized from Jeffrey Epstein for production. Over the past two days, the Government has conferred with defense counsel, who indicated this morning that they would only consent to the extension on four conditions, detailed below. Although the Government agrees to meet two of the defense conditions, it will not agree to the other two, which have no connection to the delay in discovery and no basis in law. Accordingly, the Government respectfully requests that the Court grant the extension to produce electronic discovery to November 23, 2020.

To date, the Government has produced more than 350,000 pages of discovery to the defense over the course of five productions, and the Government expects to make a sixth production by the existing November 9, 2020 deadline, as detailed below. However, the Government’s outside vendor has advised the Government that it requires additional time to prepare a seventh and final production of electronic discovery. By way of background, that final production comes from electronic devices that the Federal Bureau of Investigation (“FBI”) seized from Jeffrey Epstein’s residences in New York and the U.S. Virgin Islands in 2019. Specifically, in July of 2019, the FBI conducted multiple searches of Epstein’s residence in New York, and in August of 2019, the FBI searched Epstein’s residence in the Virgin Islands. During both searches, the FBI seized dozens of electronic devices. Pursuant to court-authorized warrants, the FBI then initiated the months-long process of gaining access to and extracting data from those devices.

In or about January of 2020, the FBI provided some, but not all, of the data from those devices to the Government. At the request of Epstein’s estate, a filter team conducted a review of that subset of data for potentially privileged materials. In or about February of 2020, the privilege team completed its review of a subset of data that the FBI had provided. In or about late February of 2020, the Government initiated a responsiveness review of that subset of data.

On June 26, 2020, the Government obtained a new warrant expanding the scope of the

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