A March 29, 2021 letter from U.S. Attorney Audrey Strauss to defense counsel in the Ghislaine Maxwell criminal case, providing discovery information about Minor Victim-4 following the superseding indictment that added sex trafficking charges.
This is an official Department of Justice letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team. The letter accompanies the second superseding indictment (S2 20 Cr. 330) and provides information about Minor Victim-4, a fourth accuser who was added to the case. The letter identifies relevant discovery materials by Bates number ranges to assist the defense in reviewing evidence related to the new allegations. The document is marked confidential under the court's protective order because it contains information about the minor victim.
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 March 29, 2021 BY ELECTRONIC MAIL New York, NY 10022 Denver, CO 80203 New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: In light of the return of superseding indictment S2 20 Cr. 330 (MN) (the "S2 Indictment"), the Government writes to provide you with information regarding the individual identified as Minor Victim-4 in the S2 Indictment. Please note that both this letter is governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records desi nated as "confidential" under the Protective Order. Minor Victim-4 was born in . To assist you in identifying portions of the discovery materials that are relevant to the new allegations contained in the S2 Indictment, below please find a list of certain Bates ranges that relate to Minor Victim-4, which were already produced to you. Please note that this list, which is being provided to you as a courtesy, is not exhaustive and does not include every portion of discovery that is relevant Minor Victim-4. EFTA00019082
Page 2 Very truly yours, AUDREY STRAUSS United States Attorney EFTA00019083



