Document EFTA00030092 is a letter from the U.S. Attorney's Office, Southern District of New York, to the defense counsel of Ghislaine Maxwell, regarding the production of discovery materials in the case United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN).
This letter, dated March 12, 2021, confirms the production of materials listed in an index, stamped with control numbers SDNY_GM_02742963 through SDNY_GM_02743100, pursuant to a court order. The materials include photographs and documents received from victims not referenced in Indictment No. Si 20 Cr. 330 and are designated as "confidential" under a protective order. The letter also acknowledges the government's ongoing discovery obligations.

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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 Sternheim, Esq. Law Offices of Bobbi C. Sternheim March 12, 2021 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY_GM_02742963 through SDNY_GM_02743100. Please note that these are the materials that the Court directed the Government to disclose by today's date in an Order dated November 18, 2020 (Dkt. No. 73). 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: Files in PDF format designated as "confidential" under the protective order have been stamped "confidential." However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. EFTA00030092
Page 2 Bates Start Bates End Summary Description Confidential Designation SDNY_GM_02742963 SDNY_GM_02743100 Photographs and documents received from victims not referenced in Indictment No. Si 20 Cr. 330 Confidential 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 U Assistant United States Attorneys EFTA00030093




