U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 21, 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 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."). Based on your request for discovery in this case, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_000 165541 through SDNY_GM_ 00174966. A reproduction of materials previously produced by the Government on August 12, 2020, which are stamped with control numbers SDNY_GM_00086557 through SDNY_GM_00096055 and SDNY GM 00164920 through SDNY_GM_00165517 is also included. The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Materials stamped with control numbers SDNY_GM_00 166247 through SDNY_GM_00166273, SDNY_GM_00 167093 through SDNY_GM_00167097, SDNY GM 00167911 through SDNY_GM 00167913, SDNY_GM_00 174366 through SDNY_GM_00174369, and SDNY_GM_00 174431 through SDNY_GM_00 174458 have been designated as "highly confidential" because they contain nude, partially nude, or otherwise sexualized images of individuals. Consistent with the Protective Order in this case, the Government is only producing these "highly confidential" materials to defense counsel and is not producing these materials directly to the defendant. 06.20.2018 EFTA00030992