U.S. Department of Justice United States Attorney Southern District of New York By Email & Hand Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. August 5, 2020 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure ("Fed. R. Crim. P."), and seeks reciprocal discovery.' Disclosure by the Government Based on your request for discovery in this case, enclosed please find copies of the materials listed in the attached index, which materials are stamped with control numbers SDNY_ GM _00000001 through SDNY_GM_00012841. Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.2 In addition to information provided herein, please note that this Office periodically posts content on social media platforms including Twitter, Facebook and YouTube. Members of the public may post comments in response to the Office's postings. We do not control these user-generated comments, nor do we monitor or regularly review such comments. You may directly access these social media platforms in the event you believe someone may have posted information relevant to this case. 2 Files in PDF format designated as "confidential" under the protective order have been stamped "confidential." However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. Such files include in their electronic names the word "Confidential," and, additionally, the bates numbers for confidential files that could not be individually labeled are included in the table below. 06.20.2018 EFTA00040593