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, Morgan and Foreman, P.C. Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim October 8, 2020 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: We write in response to your letters dated September 21, 2020 and October I, 2020 regarding the above-referenced case. 1. The Government Has Met Its Discovery Obligations As an initial matter, you repeatedly assert that the Government "has not met its discovery obligations." (Sept. 21, 2020 Ltr. at 4; Oct. I, 2020 Ltr. at 1, 3). The Government respectfully disagrees. The deadline for the production of Rule 16 discovery set by the Court, including but not limited to "electronic materials" is November 9, 2020, which is more than a month away. (Dkt. 25). The deadline for "initial non-electronic discovery, generally to include search warrant applications and subpoena returns," was due on August 21, 2020, and, as you are aware, the Government in fact made a substantial initial production before that deadline. (Id. (emphasis added)). The Government has also made substantial efforts to ensure that copies of the discovery produced to defense counsel are also available to the defendant at the Metropolitan Detention EFTA00026813