EFTA00080134

U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio!. Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
October 11, 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: 
We write to notify you that the Government may seek to introduce certain evidence at trial. 
In particular, the Government may offer certain exhibits at trial that demonstrate that, in addition 
to the defendant's conduct with Jeffrey Epstein, the defendant took steps to please other influential 
men by providing them with access to women she selected for them. For example, in one email, 
the defendant made arrangements for the Duke of York to be introduced to "pretty" girls for, as 
the defendant called it, "2 legged sight seeing." In another email, the defendant told Doug Band 
that she was arranging a dinner for him and a'
 and a' 
." We are producing these proposed ex 
its to ay, mart 
with the
 ex, 
numbers: GX 401 through 404, GX 409 through 410, and GX 413. 
In addition, please be advised that the Government may call 
as a witness 
at trial. Today, we are producing Jencks Act materials relating to Ms. 
who was employed 
by Jeffrey Epstein from approximately 2005-2006. The Government anticipates that Ms.!". 
will testify about, among other things, certain documents 
evidence relating to the 
crimes. The Government further anticipates that Ms. 
will testify 
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This evidence is admissible as direct evidence of the crimes charged and, in the alternative, 
pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, 
and/or absence of mistake of accident with respect to the charges in the above-referenced case. 
Because this evidence is admissible as direct evidence, the Government is not planning to 
affirmatively move in limine to seek its admission. 
Please note that this letter and the information contained herein is governed by the July 31, 
2020 Protective Order in this case. This letter is itself designated as "confidential" under the 
Protective Order. 
Very truly yours, 
DAMIAN WILLIAMS 
United States Attorney 
by:  
/s 
Assistant United States Attorneys 
EFTA00080135