COHEN & GRESSER LLP December 28, 2020 BY EMAIL. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: 800 Third Pianos New York, NY 10022 ♦1 212 957 7600 phono www colsmipossoo corn On behalf of our client, Ghislaine Maxwell, we hereby request that the government file a Bill of Particulars pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure. Please let us know by January 4, 2021 whether it will be necessary to raise any aspect of this request with the Court. We request clarification of the allegations specified below in order to permit Ms. Maxwell to prepare her defense and avoid unfair surprise at trial. See United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). The Superseding Indictment does not sufficiently inform Ms. Maxwell of the specific conduct of which she is accused. Accordingly, we request the following particulars regarding the indicated paragraphs of the Superseding Indictment: I. Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3 7, II, 13, 17, 19). 2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-1 7a). 3. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" Minor Victim-1 "to engage in sexual acts with Epstein" (¶ 7a). 4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-1 7a). EFTA00030934