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 October 11, 2021 BY ELECTRONIC MAIL New York, NY 10022 New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Today the Government is producing materials, including Jencks Act and Giglio material, regarding the witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today’s production. The Government notes that the records stamped 3522-004 reflect testified in the grand jury in connection with the investigation conducted by the Palm Beach State's Attorney’s Office, but the clerk of court has cqp figs e Government that the audio files are unplayable and, therefore, there is no record ae jury testimony. The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial. Instead, these materials contain, among other things, certain witness statements. Enclosed please find an index detailing these materials. This production should not be taken to indicate that the Government believes it EFTA00025287

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Page 2 has any obligation to provide all of these materials; rather, we make this production as a courtesy. Moreover, although the Government presently does not intend to call the individuals listed in the enclosed index, we reserve the right to do so and will notify you should the Government determine that it intends to call any of these individuals at trial. The Govern highlight for you a particular portion of statements made by non-testifying witness about Minor Victim-4. In particula as previously stated to law enforcement, in sum and substance, that Minor Victim-4 introduced o Jeffrey Epstein and instructed] to tell Epstein that fi was 18 years old. These statements by a... contained in the Government’s non-testifying witness productions, including in the first such production dated April 12, 2021 (see, e.g., 3501.149-023 at 1; 3501.149-026 at 9; and 3501.149-024 between approximately timestamp 04:20 and timestamp 07:30). Please note that this letter, the enclosed indices, and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. In particular, the entire production is designated as “confidential” under the Protective Order. The index is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word “confidential” in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: “SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17.” This marking directly refers to the specific paragraphs of the Protective Order that govern today’s production. Additionally, please note that many of the individuals referenced in this production are represented by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. The Government also writes to notify you of the following matters regarding certain witnesses that the Government may call to testify at trial in the above-referenced case: se ° 2 3 provided transportation to and from the airport for trial preparation sessions. The FBI will similarly provide transportation (of nen she travels to New York for trial testimony. o The U.S. Attorney’s Office for the Southern District of New York (the “USAO SDNY”) paid for travel to and from a trial preparation session, including hotel Pe USAO SDNY will similarly pay travel and hotel expenses when o The USAO SDNY to accompany i i ssions in New York. The USAO SD} to accompany o New York in connection with EFTA00025288

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Page 3 o .The USAO SDNY _paid for a car to take o The FBI provided meals and snacks to i os trial preparation sessions. oO _ A. SDNY will pay travel and hotel expenses when | Ee to New York to testify at trial. e ° : USAO SDNY paid ol travel to and from a witness interview with the Government in New York, including hotel : . The USAO SDNY will similarly pay travel and hotel expenses wheal avels to New York to testify at trial. e ° 1: | = a. paid for travel to and from an August 2019 court hearing before Judge Berman, including hoteLex o The FBI paid for therapy sessions fo} o The USAO SDNY will pay travel and hotel expenses wher ravels to New York to testify at trial. e oO | ls SDNY paid for | = travel to and from a trial preparation session in New York. o The USAO SDNY will pay travel and hotel expenses whe ff avers to New York to testify at trial. e ° - a provided transportation to and from the airport for_trial preparation sessions. The FBI will similarly provide transportation for for trial testimony. o The USAO SDNY paid for travel to and from a trial preparation session in New York, including hotel oo USAO SDNY will similarly pay travel I and hotel expenses when trav ° melt AO SDNY paid for lunch for uring trial preparation sessions that took place at mealtimes. ° ps o The FBI has paid for transportation for | car to and from trial preparation sessions. EFTA00025289

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Page 4 o The USAO SDNY will pay travel and hotel expenses whenf cavers to New York to testify at trial. o The USAO SDNY provided a letter EEE oye confirming dates of trial preparation sessions and has agreed to similarly provide a letter to his employer regarding dates of future trial preparation sessions and trial testimony. a7 o The USAO SDNY paid ~~ travel to and from a trial preparation session in New York, including hotel expenses. The USAO SDNY will similarly pay travel and hotel expenses whe avels to New York to testify at trial. e ° Z wh SDNY paid for «0 travel to and from two trial preparation sessions in New York, including hotel exp, webtie USAO SDNY will similarly pay travel and hotel expenses when ravels to New York to testify at trial. The USAO SDNY paid for a. travel to and from a trial preparation session in New York, including hotel expenses. The USAO SDNY will similarly pay travel and hotel expenses wher travels to New York to testify at trial. specialists to all victims, including The victim services offered included counseling, assistance with finding appropriate therapy, and assistance with determining available public benefits and other resources available to crime victims. e The USAO SDNY has offered—or will offer—to provide transportation to and/or from and hotel accommodations in New York City in connection with the trial testimony of the witnesses the Government anticipates testifying at the trial. Such arrangements have not yet been finalized. The USAO SDNY anticipates that it will pay travel and hotel expenses for trial testimony for at least the following individuals: EFTA00025290

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Very truly yours, DAMIAN WILLIAMS United States Attorney by: __s/ Assistant od States Attorneys Page 5 EFTA00025291