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 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 (AJN) Dear Counsel: We write in response to your March 8, 2021 letter, which requests the disclosure of: (1) documents produced to Radar Online in the matter of Radar Online v. FBI, 17 Civ. 3956 (PGG); (2) "any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell"; and (3) "any materials that reflect the involvement of the FBI-New York Office in the USAO-SDFL investigation." We address each request in turn below. First, you have requested that we produce to you all materials that were produced to Radar Online pursuant to the Freedom of Information Act ("FOIA") in connection with the civil lawsuit Radar Online v. FBI, 17 Civ. 3956 (PGG). As an initial matter, your letter fails to articulate any legal basis for that request under Rule 16, or any other law governing criminal discovery. Moreover, to the extent that you assert that you need to know when information received by Radar Online through FOIA may have been published by the media, any information about the date of publication would presumably be publicly available and, in any event, not information within the Government's possession, custody or control. EFTA00019599