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nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD,
contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pi
w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition o
th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recog
siveness review of images from this device until November 17, 2020. Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Governm
nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD,
contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pi
w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition o
th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recog
siveness review of images from this device until November 17, 2020. Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Governm
w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition o
th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recog
nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD,
contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pi
siveness review of images from this device until November 17, 2020. Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Governm
w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition o
th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recog
nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD,
contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pi
siveness review of images from this device until November 17, 2020. Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Governm
th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recog
nue Denver, CO 80203 Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD,
contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pi
w York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In recognition o
siveness review of images from this device until November 17, 2020. Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Governm
Date: Wed, 13 Jan 2021 06:05:35 +0000 Embedded: Discovery_Requests.msg Inline-Images: image001.jpg; image002.jpg I write to again request that Ms. Maxwell be given access to the laptop computer on the weekends. She recently informed us that the prison computer can't read a substantial portion of the ma
.jpg; image002.jpg I write to again request that Ms. Maxwell be given access to the laptop computer on the wee
renew our discovery requests set forth in our 1/7/2021 email (see attached). In particular, we would like to receive as soon as possible the list of Subject Devices in request #3. When can we expect to receive that? Regards, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022
0:05 PM To: EFTA00030929 (USANYS) Cc: Subject: RE: Discovery Requests Below please find our responses. 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery produced to date. It took a significant amount of time to create this copy du
ur responses. 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full
he contents of the CD produced on November 18, 2020. 3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was extracted. In our November 18, 2020 disco
ubject: RE: Discovery Requests Chris, Below please find our responses. ; Bobbi Sternheim c ) Jeff Pagliuca 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full set of the discovery produced to date. It took a significant amount of time to create this copy du
Jeff Pagliuca 1. As we have recently discussed, Ms. Maxwell now has access to the 4TB drive containing a full
he contents of the CD produced on November 18, 2020. 3. As I conveyed to you over the phone and in a recent email, the materials produced from the Subject Devices all contain metadata indicating the "NYC" CART Evidence Number of the device from which each document was extracted. In our November 18, 2020 disco
Entities connected to both Ghislaine Maxwell and Subject Devices

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Denver
LOCATION
Audrey Strauss
PERSON
Christian Everdell
PERSONCohen & Gresser LLP
ORGANIZATIONBates
PERSON
Foreman
PERSONHaddon
PERSONMark Cohen
PERSONThe Silvio J. Mollo Building
ORGANIZATIONBobbi Stemheim
PERSONthe District of New Hampshire
LOCATIONBates Stan
PERSONBates End
ORGANIZATION