EFTA00026813.pdf

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pdf

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data-set-8

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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 Stemheim, Esq. 
Law Offices of Bobbi C. Stemheim 
October 8, 2020 
Re: 
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 
Dear Counsel: 
We write in response to your letters dated September 21, 2020 and October I, 2020 
regarding the above-referenced case. 
1. The Government Has Met Its Discovery Obligations 
As an initial matter, you repeatedly assert that the Government "has not met its discovery 
obligations." (Sept. 21, 2020 Ltr. at 4; Oct. I, 2020 Ltr. at 1, 3). The Government respectfully 
disagrees. The deadline for the production of Rule 16 discovery set by the Court, including but 
not limited to "electronic materials" is November 9, 2020, which is more than a month away. (Dkt. 
25). The deadline for "initial non-electronic discovery, generally to include search warrant 
applications and subpoena returns," was due on August 21, 2020, and, as you are aware, the 
Government in fact made a substantial initial production before that deadline. (Id. (emphasis 
added)). 
The Government has also made substantial efforts to ensure that copies of the discovery 
produced to defense counsel are also available to the defendant at the Metropolitan Detention 
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Center ("MDC"). And while there have been technical difficulties with certain of the productions 
made to the defendant, the Government understands that defense counsel is able to access all of 
the material, and, as detailed herein, we have worked promptly to address each concern you have 
raised with respect to productions made directly to the defendant. In sum, your claim that the 
Government has not met its discovery obligations because of the delay caused by your requests to 
reformat and rebum the discovery is simply inaccurate. The Go…

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