EFTA00081924.pdf

U.S. Department of Justice United States Attorney Southern District ofNew York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 September 29, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R Crim. P."). Based on your request for discovery in this case, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY GM_000174967 through SDNY GM 00328069. 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: 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." 06.20.2018 EFTA00081924  Page 2 Bates Start Bates End Summary Description Confidential Designation SDNY_GM_00174967 SDNY_GM_00270985 Deutsche Bank records Confidential SDNY GM 00270986 SDNY GM 00323934 JPMorgan Chase records Confidential SDNY GM 00323935 SDNY GM 00324015 GM Documents SDNY GM 00324016 SDNY GM 00324036 Citibank records for Ghislaine Maxwell UBS records for Angara Trust, Montepelier Trust, Terramar Project, Inc., Max Foundation, Ghislaine Maxwell, Ghislaine SDNY_GM_00324037 SDNY_GM_00325754 Maxwell IRA, & Ellmax, LLC SDNY_GM 00325755 SDNY_GM 00325761 LSJ Scene2Go American Express records for Jeffrey SDNY_GM_00325762 SDNY_GM_00328069 Epstein and Ghislaine Maxwell Confidential 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, Actin United States Attorne by: States Attorneys 06.20.2018 EFTA00081925