U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York. New York 10007 September 15, 2021 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 Sternheim, 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 (AJN) Dear Counsel: The Government expects to offer testimony from Computer Forensic Examiner of the Federal Bureau of Investigation's ("FBI") Com uter Analysis Response Team ("CART"). Although the Government believes that Examiner testimony will not require admission through Rule 702 of the Federal Rules of Evidence, the Government nevertheless provides notice f Examiner anticipated testimony in an abundance of caution. A copy of Examiner curriculum vitae is being produced to you today bearing Bates number 3503- 001.' The Government anticipates that, if called as a witness, Examiner will testify about his extraction of devices seized pursuant to court-authorized search warrants; user information associated with certain of those devices; and documents and photographs extracted from certain ' Examiner has previously testified regarding similar topics in federal court. As a courtesy, the Government notifies you that Examiner has previously testified in federal court in United States v. DiTomasso, 14 Cr. 160 (SAS), United States v. Hirst, 15 Cr. 643 (PKC), United States v. Stash', 18 Cr. 259 (PKC), and United States v. Kelly, 19 Cr. 286 (AMD) (E.D.N.Y.). EFTA00099133