EFTA00030092.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of Justice
United States Attorney
Southern District of New York
BY ELECTRONIC MAIL
Christian Everdell, Esq.
Mark Cohen, Esq.
Cohen & Gresser LLP
Laura Menninger, Esq.
Jeffrey Pagliuca, Esq.
Haddon. Morgan and Foreman, P.C.
Bobbi Sternheim, Esq.
Law Offices of Bobbi C. Sternheim
March 12, 2021
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_02742963 through SDNY_GM_02743100. Please
note that these are the materials that the Court directed the Government to disclose by today's date
in an Order dated November 18, 2020 (Dkt. No. 73).
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.
EFTA00030092

Page 2
Bates Start
Bates End
Summary Description
Confidential
Designation
SDNY_GM_02742963
SDNY_GM_02743100
Photographs and documents received
from victims not referenced in
Indictment No. Si 20 Cr. 330
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
U
Assistant United States Attorneys
EFTA00030093

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