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 August 5, 2020 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."), and seeks reciprocal discovery.' Disclosure by the Government Based on your request for discovery in this case, enclosed please find copies of the materials listed in the attached index, which materials are stamped with control numbers SDNY GM 00000001 through SDNY_GM_00012841. If you wish to inspect any of the physical evidence referenced in these materials, including items listed on search inventories, please let us know, and we will make arrangements for you to do so. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. Pursuant to those obligations, we are disclosing the information below. This disclosure should not be taken to indicate that the Government believes the enclosed information constitutes Brady material. Rather, we make this disclosure in an abundance of caution. Specifically, the Government discloses the following: • The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court. In addition to information provided herein, please note that this Office periodically posts content on social media platforms including Twitter, Facebook and YouTube. Members of the public may post comments in response to the Office's postings. We do not control these user-generated comments, nor do we monitor or regularly review such comments. You may directly access these social media platforms in the event you believe someone may have posted information relevant to this case. 06.20.2018 EFTA00017085