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. Neu• York 10007 November 25, 2021 BY ELECTRONIC MAIL Christian Everdell, 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 Stemheim, 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 fro of the Federal Bureau of Investigation's ("FBI") Computer Analysis Response Team ("CART"). As noted in the Government's September 15, 2021 letter, although the Government believes that testimony will not require admission through Rule 702 of the Federal Rules of Evidence, the Government provided ex rt notice. In an abundance of caution, the Government is providing additional description of anticipated testimony. The Government anticipates that will testify regarding the forensic examination of the devices marked for identification as Government Exhibits 54 and 55, and his determination that those exhibits are clones. He is ex ted to testify that a clone is an exact copy of one piece of media to another. is expected to explain that he connected Government Exhibits 54 and 55 to a write blocker and subs uentl ima ed, or made an exact copy, of the exhibits. The Government anticipates that will explain that the images of Government Exhibits 54 and 55 are exact copies of the original devices because he ran a hash, or mathematical algorithm that uniquely identifies data, on the original devices and the images, which are identical. EFTA00156626