EFTA00029632.pdf

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pdf

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data-set-8

Original source

Extracted text

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 13, 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 
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_ 00012842 through SDNY_GM_ 00165540. The materials are 
available for pickup at the U.S. Attorney's Office in Manhattan. Additionally, to aid in the 
preparation of the defense, the Government hereby provides notice of the month and year in which 
the minor victims listed in the Indictment in the above-referenced case were born. Minor Victim-
1 was born in August of 1980. Minor Victim-2 was born in July of 1979. Minor Victim-3 was 
born in March of 1977. 
Please note that both this letter and enclosed materials are governed by the July 31, 2020 
Protective Order in this case.' This letter is itself designated as "confidential," because it 
includes witness-identifying information and information regarding records designated as 
"confidential" under the Protective Order. 
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 
EFTA00029632


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