COHEN & GRESSER LLP October 1, 2020 BY EMAIL Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write once again to express our dissatisfaction that the government still has not provided a complete set of readable discovery materials to Ms. Maxwell in the MDC. We have now had several phone calls and emails to discuss the problems with the discovery, but the problems still are not fixed. It is now over five weeks since the August 21 discovery deadline set by the court and the government still has not met its discovery obligations. That is simply not acceptable. In our previous letter, dated September 21, 2020, we outlined for you the numerous problems that Ms. Maxwell had been having with unreadable discovery files since she first began receiving the government's productions in the MDC in August 2020. This was a continuation of the same problem we identified for you in our letter, dated August 27, 2020, when we requested a new set of the discovery materials that were fully readable. On September 22, 2020, we had a conference call to discuss these issues. On that call, you stated that you were trying to address the readability problems, but that in the meantime, defense counsel could, among other things, create a laptop computer with a full copy of the discovery saved locally that defense counsel could bring to the MDC so that Ms. Maxwell could use it to review the unreadable discovery. You also notified us that there were approximately 40,000 non- nude photographs and images, and thousands of nude or partially nude images, which had been seized from Jeffrey Epstein's residences in New York and the Virgin Islands pursuant to search warrants, and which you had referenced in your August 21, 2020 production cover letter. You further advised that you were in the process of scanning those images so that you could produce any documents not marked Highly Confidential in electronic format. Finally, in response to our request that Ms. Max