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 October 12, 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: We write to notify you that the Government may seek to introduce certain evidence at trial. In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition to the defendant's conduct with Jeffrey Epstein, the defendant took steps to provide other men with access to women. We are producing these proposed exhibits today, marked with the following exhibit numbers: [list]. In addition, please be advised that the Government may call as a witness at trial. Today, we are producing Jencks Act materials relating to Ms. who was ern, by Jeffrey Epstein from approximately 2005-2006. The Government anticipates that Ms. will testify about, among other things, certain documentary evidence relating to the charged crimes. The Government further anticipates that Ms. will testify about her role in scheduling sexualized massages for Jeffrey Epstein with underage girls. This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of accident with respect to the charges in the above-referenced case. EFTA00021685