Sar U.S. Department of Justice mn S . ~/ United States Attorney Southern District of New York August 5, 2020 By Email & Hand Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP a Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, — and Foreman, P.C. Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) 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.’ ' 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. ? 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

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Page 2 This letter is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order. The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government will provide material under Giglio v. United States, 405 U.S. 150, 154 (1972), and its progeny, in a timely manner prior to trial and consistent with the schedule set by the Court. Disclosure by the Defendant In light of your request for discovery in this case, the Government hereby requests reciprocal discovery under Fed. R. Crim. P. 16(b). Specifically, we request that you allow inspection and copying of: (1) any books, or copies or portions thereof, which are in the defendant’s possession, custody or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial; and (2) any results or reports of physical or mental examinations and of scientific tests or experiments made in connection with this case, or copies thereof, which are in the defendant’s possession or control, and which the defendant intends to introduce as evidence or otherwise rely on at trial or which were prepared by a witness whom the defendant intends to call at trial. The Government also requests that the defendant disclose prior statements of witnesses he will call to testify. See Fed. R. Crim. P. 26.2; United States v. Nobles, 422 U.S. 225 (1975). We request that such material be provided on the same basis upon which we agree to supply the defendant with 3500 material relating to Government witnesses. Sentence Reduction for Acceptance of Responsibility This Office will oppose the additional one-point reduction under the Sentencing Guidelines available for defendants who plead prior to the Government’s initiation of trial preparations pursuant to U.S.S.G. § 3E1.1(b), in the event your client has not entered a plea of guilty six weeks prior to trial, or prior to the provision of 3500 material, whichever is earlier. We will follow this policy whether or not suppression or other pretrial motions remain outstanding after this date and even if the trial date has not been announced by the Court six weeks in advance of the trial. Finally, please be advised that pursuant to the policy of the Office concerning plea offers, no plea offer is effective unless and until made in writing and signed by authorized representatives of the Office. In particular, discussions regarding the pretrial disposition of a matter that are not reduced to writing and signed by authorized representatives of the Office cannot and do not constitute a “formal offer” or a “plea offer,” as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 06.20.2018 EFTA00040594

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Page 3 SDNY_GM_00000001 | SDNY_GM_00000002 Ghislaine Maxwell Joint Automated Booking System Summary SDNY_GM_00000003 | SDNY_GM_00000044 Pen Register Orders and Applications SDNY_GM_00000045 | SDNY_GM_00000717 Search Warrants and Confidential Applications SDNY_GM_00000718 | SDNY_GM_00000833 Immigration and Travel Records for Jeffrey Epstein and Ghislaine Maxwell SDNY_GM_00000834 | SDNY_GM_00000905 Unsealing materials Confidential pertaining to 15 Civ. 7433 RWS), 19 Misc. 149 (CM SDNY_GM_00000906 | SDNY_GM_00000962 Unsealing materials Confidential pertaining to 17 Civ. 0616 (SN), 19 Misc. 179 (SN) SDNY_GM_00000963 | SDNY_GM_00000964 | SDNY_GM_ 00000963 Airline Reporting Confidential Corporation records SDNY_GM_00000965 | SDNY_GM_00000965 Alaska Airlines records Confidential SDNY_GM_00000966 | SDNY_GM_00000976 | SDNY_GM_ 00000967; Amazon Records Confidential SDNY_GM_ 00000969; SDNY_GM_ 00000971; SDNY_GM_ 00000973; SDNY_GM_ 00000974; SDNY_GM_ 00000976 SDNY_GM_00000977 | SDNY_GM_00001012 American Airlines records _| Confidential SDNY_GM_00001013 | SDNY_GM_00001014 | SDNY_GM_00001014 Apple Records for Jeffrey | Confidential Epstein SDNY_GM_00001015 | SDNY_GM_00003637 AT&T Records Confidential SDNY_GM_00003638 | SDNY_GM_00003701 Bank of America Records Confidential SDNY_GM_00003702 | SDNY_GM_00003702 Century Link Records for Confidential the numbe: SDNY_GM_00003703 | SDNY_GM_00004639 | SDNY_GM_00004511 Citibank Records Confidential SDNY_GM_00004640 | SDNY_GM_00004649 Delaware Division of Corporations Records relating to LSJ LLC SDNY_GM_00004650 | SDNY_GM_00004655 Delta Airlines Records Confidential SDNY_GM_00004656 | SDNY_GM_00004656 Confidential School Records SDNY_GM_00004657 | SDNY_GM_00004657 Expedia Records SDNY_GM_00004658 | SDNY_GM_00004721 Confidential SDNY_GM_00004722 | SDNY_GM_00004762 Gold Coast Federal Credit | Confidential Union records Ss DNY_GM_00004763 | SDNY_GM_00004776 Google records regarding Confidential account information for Jeffrey Epstien and Ghislaine Maxwell SDNY_GM_00004776 | SDNY_GM_00004781 Instagram records | 06.20.2018 EFTA00040595

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SDNY_GM_00004782 | SDNY_GM_00005414 SDNY_GM_00005415 | SDNY_GM_00005416 Page 4 Records MCC Request for Emails Confidential SDNY_GM_00005417 | SDNY_GM_00005417 Microsoft Records regarding account information for Jeffrey Epstein SDNY_GM_0005418 | SDNY_GM_00005444 SDNY_GM_00005431; SDNY_GM_00005432; SDNY_GM 00005433; SDNY_GM_00005435 SDNY_GM_00005445 | SDNY_GM_00005484 MoneyGram Records Confidential relating to Ghislaine Maxwell, and New York State | Department of State records SDNY_GM_00005485 | SDNY_GM_00005491 SDNY_GM_00005492 | SDNY_GM_00005531 SDNY_GM_00005487; SDNY_GM_00005488; SDNY_GM_00005490; SDNY_GM_00005491 Oath Holdings records for | Confidential Jeffrey Epstein email accounts Confidential | School Records SDNY_GM_00005532 | SDNY_GM_00005676 SDNY_GM_00005677 | SDNY_GM_00006060 SDNY_GM_00006007; SDNY_GM_00006008; SDNY_GM_00006009 SDNY_GM_00006010 Flight manifests and Confidential records from David Rodgers, 1991 - 2013 Charles Schwab Records Confidential SDNY_GM_00006061 | SDNY_GM_00006079 | Shoppers Travel Records Confidential SDNY_GM_00006080 | SDNY_GM_00006096 Southwest Records Confidential SDNY_GM_00006097 | SDNY_GM_00006129 Capital One Records Confidential SDNY_GM_ 00006130 | SDNY_GM_00007425 __TD Bank Records Confidential SDNY_GM _00007426 | SDNY_GM_00007641 SDNY_GM_ 00007521 SDNY_GM_ 00007580; SDNY_GM_00007620 SDNY_GM_ 00007641 PayPal Records Confidential SDNY_GM_00007642 | SDNY_GM_00007677 SDNY_GM_00007678 | SDNY_GM_00008136 SDNY_GM _00007642 SDNY_GM_00007654 SDNY_GM_00007658; SDNY_GM_00007666; SDNY_GM_00007676; SDNY_GM_00007677 T-Mobile records Confidential Materials from Darren Confidential Indyke and Richard Kahn (Epstein Estate Executors) SDNY_GM_00008137 | SDNY_GM_00008137 UMB Bank no records Confidential | notification SDNY_GM_00008138 | SDNY_GM_00008146 United Airlines records Confidential SDNY_GM_00008147 | SDNY_GM _00010164 SDNY_GM_ 00009087; SDNY_GM_00009088 UBS Bank records Confidential SDNY_GM_00010165 | SDNY_GM_00010355 USAA records ( 06.20.2018 EFTA00040596

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Page 5 SDNY_GM_00010356 SDNY_GM_00010456 U.S. Virgin Islands Division of Corporations records for Laurel Inc, Maple Inc, and Nautilus, Inc Confidential | SDNY_GM_00010457 SDNY_GM_00010460 SDNY_GM_00010459 SDNY_GM_00010461 Venmo records Verizon records | Confidential Confidential SDNY_GM_ 00010462 /SDNY_GM_00011484 SDNY_GM_00011483 SDNY_GM_00011488 Flight manifest records | from Lawrence Visoki Western Union record of no accounts found Confidential | Confidential SDNY_GM_00011489 SDNY_GM_00012474 SDNY_GM_00011489; SDNY_GM_00011490; SDNY_GM_00012217; SDNY_GM_00012220; SDNY_GM_00012305; SDNY_GM_00012359; SDNY_GM_00012382; SDNY_GM_00012396 SDNY_GM_00012405 SDNY_GM_00012435 TD Ameritrade Materials SDNY_GM_00012475 Enclosure SDNY_GM_00012841 Very truly yours, Materials from Confidential Acting United States Attorney Assistant United States Attorneys Confidential 06.20.2018 EFTA00040597