EFTA00099164.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Sihlo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 March 29, 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 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 light of the return of superseding indictment S2 20 Cr. 330 (AJN) (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 designated 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. • SDNY_GM_00165560 • SDNY_GM_00165644 • SDNY_GM_00165654 EFTA00099164 Page 2 • SDNY_GM_00165656 - SDNY_GM_00165659 • SDNY_GM_00 165669 - SDNY_GM_00 165670 • SDNY_GM_00 165674 • SDNY_GM_00165691 - SDNY_GM_00 165692 • SDNY_GM_00165701 • SDNY_GM_00165752 • SDNY_GM_00165776 • SDNY_GM_00365036 - SDNY_GM_00365049 • SDNY_GM_00381010 - SDNY_GM_00381013 • SDNY_GM_00381020 - SDNY_GM_00381023 • SDNY_GM_00394866 • SDNY_GM_00431558 • SDNY_GM_00449302 • SDNY_GM_00459391 • SDNY_GM_00459405 • SDNY_GM_00459416 • SDNY_GM_00459430 • SDNY_GM_00459444 • SDNY_GM_00459455 • SDNY_GM_00525482 • SDNY_GM_01987478 • SDNY_GM_02735989 • SDNY_GM_02742303 - SDNY_GM_2742395 • SDNY_GM_02743100 Very truly yours, AUDREY STRAUSS United States Attorney by: ------ ____-------'"------ ------------ ,..--.----... Assistant United States Attorneys EFTA00099165