EFTA00030992.pdf

Type: pdf
Source set: data-set-8

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 21, 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_000 165541 through SDNY_GM_ 00174966. A reproduction
of materials previously produced by the Government on August 12, 2020, which are stamped with
control
numbers
SDNY_GM_00086557
through
SDNY_GM_00096055
and
SDNY GM 00164920 through SDNY_GM_00165517 is also included. The materials are
available for pickup at the U.S. Attorney's Office in Manhattan.
Materials
stamped
with
control
numbers
SDNY_GM_00 166247
through
SDNY_GM_00166273,
SDNY_GM_00 167093
through
SDNY_GM_00167097,
SDNY GM 00167911
through
SDNY_GM 00167913,
SDNY_GM_00 174366
through
SDNY_GM_00174369, and SDNY_GM_00 174431 through SDNY_GM_00 174458 have been
designated as "highly confidential" because they contain nude, partially nude, or otherwise
sexualized images of individuals.
Consistent with the Protective Order in this case, the
Government is only producing these "highly confidential" materials to defense counsel and is not
producing these materials directly to the defendant.
06.20.2018
EFTA00030992

Page 2
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 …

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