rot U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 11, 2021 BY ELECTRONIC MAIL Esq. E. . New York, NY 10022 Esq. Denver, CO 80203 Es . w ices o ew ork. NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing materials, including Jencks Act and Giglio material, regarding the witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today's production. The Government notes that the records stamped 3522-004 reflect tha testified in the grand jury in connection with the investigation conducted by the Pam eac tate s Attorney's Office, but the clerk of court has c Government that the audio files are unplayable and, therefore, there is no record o nd jury testimony. The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial. Instead, these materials contain, among other things, certain witness statements. Enclosed please find an index detailing these materials. This production should not be taken to indicate that the Government believes it EFTA00025287