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Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 1 of 8
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 7, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter to provide additional information in
response to the Court’s prior inquiry regarding the Government’s plan to obtain and review other
investigative files, created and maintained by other offices, which are related to the above-
referenced case. In particular, at the initial conference in this matter on July 14, 2020, the Court
asked the Government about its plan to ensure timely review the files of other agencies for potential
disclosures in this case and highlighted the Court’s expectation that the Government would be
thoughtful and probing in its assessment of such a review. Consistent with the Government’s
commitment to take a thorough and transparent approach to its disclosure obligations, this letter
outlines the relevant investigative files of which the Government is currently aware and describes
the Government’s approach as to each.
1. Background Regarding the Government’s Rule 16 Discovery Productions
The charges in this case arise out of an investigation conducted by the United States
Attorney’s Office for the Southern District of New York (“USAO-SDNY’”), the Federal Bureau of
Investigation (“FBI”) New York Office, and the New York Police Department (the “NYPD”’)
(collectively, the “Prosecution Team’). That investigation was opened in 2018 and remains
ongoing. The Government has copies of the full investigative files for this case from the USAO-
SDNY, the FBI New York Office, and the NYPD (the “Prosecution Team Files”). The bulk of the
productions to date have come from the Prosecution Team Files. The Government is continuing
to review the Prosecution Team Files for any additional materials that warrant disclosure.
Specifically, to date, the Government has produced approximately 328,863 pages of
discovery to the defense in this case. Those materials include, among other things, photographs,
documents seized during searches, search warrants, search warrant applications, financial records,
travel records, property records, phone records, law enforcement reports, and other subpoena
DOJ-OGR-00001787