U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 8, 2020 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 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 EFTA00026819