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 Mor an and Foreman, P.C. Dear Counsel: The Silvio I. Motto Building January 10, 2021 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) We write in response to your letter of December 28, 2020, in which you request a bill of particulars in the above-captioned matter. As set forth herein, the Government does not intend to provide further particulars because under the well-established law of this Circuit it has no obligation to do so. To the contrary, and as you are aware, the Government outlined its charges against your client in a detailed speaking superseding indictment (the "Indictment") and has since provided considerable additional information through the production of to date of over 2.7 million items of discovery, all in electronic form and accompanied by an index. Accordingly, the Government has more than provided the defendant with adequate notice of the charges against her, and no further particulars are required. "A bill of particulars is required only where the charges of the indictment are so general that they do not advise the defendant of the specific acts of which he is accused." United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug. 26, 2014) (same); United States v. Mandell, 710 F. Supp. 2d 368, 384 (S.D.N.Y. 2010) (same). "Acquisition of evidentiary details is not the function of the bill of particulars." United States v. Toms, 901 F.2d 205, 234 (2d Cir. 1990), abrogated on other grounds by United States v. Marcus, 628 F.3d 36, 41 (2d Cir. 2010) (quotations marks and citation omitted). EFTA00023910