EFTA00028733.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 May 20, 2021 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 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02753432 through SDNY_GM_02753551 and SDNY GM SUPP 00219450 through SDNY_GM_SUPP_00219451. Regarding the materials stamped with control numbers SDNY_GM_02753529 through SDNY_GM_02753551, these folders contain native image files from several devices that correspond with images previously produced to you in PDF format on November 9, 2020. The enclosed spreadsheet indicates which control numbers with "SDNY_GM_SUPP" prefixes correspond with these native "carved" images. The enclosed spreadsheet also details the original file names of the "carved" files that were previously produced to you in their native format, also on November 9, 2020. 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: EFTA00028733 Page 2 Bates Start Bates End Summary Description Confidential Designation SDNY GM 02753432 SDNY GM 02753528 Interlochen records Confidential SDNY_GM_02753529 SDNY_GM_02753529 Native "carved" images previously produced in PDF format for device NYCO24321 Confidential SDNY_GM_02753530 SDNY_GM_02753530 Native "carved" images previously produced in PDF format for device NYCO24323 Confidential SDNY GM 02753531 SDNY GM 02753531 Native "carved" images previously produced in PDF format for device NYCO24324 Confidential SDNY_GM_02753532 SDNY_GM_02753532 Native "carved" images previously produced in PDF format for device NYCO24326 Confidential SDNY_GM_02753533 SDNY_GM_02753533 Native "carved" images previously produced in PDF format for device NYCO24332 Confidential SDNY GM 02753534 SDNY GM 02753534 Native "carved" images previously produced in PDF format for device NYCO24336 Confidential SDNY_GM_02753535 SDNY_GM_02753535 Native "carved" images previously produced in PDF format for device NYCO24337 Confidential SDNY_GM_02753536 SDNY_GM_02753536 Native "carved" images previously produced in PDF format for device NYCO24340 Confidential SDNY_GM_02753537 SDNY_GM_02753537 Native "carved" images previously produced in PDF format for device NYCO24341 Confidential SDNY_GM_02753538 SDNY_GM_02753538 Native "carved" images previously produced in PDF format for device NYCO24343 Confidential SDNY_GM_02753539 SDNY_GM_02753539 Native "carved" images previously produced in PDF format for device NYCO24348 Confidential EFTA00028734 Page 3 SDNY_GM_02753540 SDNY_GM_02753540 Native "carved" images previously produced in PDF format for device NYCO24349 Confidential SDNY_GM_02753541 SDNY_GM_02753541 Native "carved" images previously produced in PDF format for device NYCO24350 Confidential SDNY_GM_02753542 SDNY_GM_02753542 Native "carved" images previously produced in PDF format for device NYCO24351 Confidential SDNY_GM_02753543 SDNY_GM_02753543 Native "carved" images previously produced in PDF format for device NYCO24363 Confidential SDNY_GM_02753544 SDNY_GM_02753544 Native "carved" images previously produced in PDF format for device NYCO24368 Confidential SDNY_GM_02753545 SDNY_GM_02753545 Native "carved" images previously produced in PDF format for device NYCO24370 Confidential SDNY_GM_02753546 SDNY_GM_02753546 Native "carved" images previously produced in PDF format for device NYCO24372 Confidential SDNY_GM_02753547 SDNY_GM_02753547 Native "carved" images previously produced in PDF format for device NYCO24384 Confidential SDNY_GM_02753548 SDNY_GM_02753548 Native "carved" images previously produced in PDF format for device NYCO24386 Confidential SDNY_GM_02753549 SDNY_GM_02753549 Native "carved" images previously produced in PDF format for device NYCO24388 Confidential SDNY_GM_02753550 SDNY_GM_02753550 Native "carved" images previously produced in PDF format for device NYCO24392 Confidential SDNY_GM_02753551 SDNY_GM_02753551 Native "carved" images previously produced in PDF format for device NYCO27910 Confidential SDNY GM SUPP 00219450 _ _ _ SDNY GM SUPP 00219450 _ _ _ Image from device NYCO24329 Confidential EFTA00028735 Page 4 SDNY GM SUPP 00219451 SDNY GM SUPP 00219451 Image from device Confidential _ _ _ _ _ _ NYCO24366 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 United States Attorney by: Assistant United States Attorneys EFTA00028736