Epstein Secrets

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-vorkinv- jeffrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszu- story.

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00066067 October 13, Page 3 10. We request that the government produce a complete copy of the diary, only seven pages of w

s Attorney's Office w York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on beha

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.rntdailvnews.com/new-vork/nv- jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu- storv

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00084864 October 13, 2020 Page 3 10. We request that the government produce a complete copy of the diary, only seven pages

s Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

tes Attorney's Office York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on beha

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-vork/nv- jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu- story.

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00087048 October 13, Page 3 10. We request that the government produce a complete copy of the diary, only seven pages of w

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nvdailvnews.com/new-vork/ny- jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu- storv.

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00089611 October 13, 2020 Page 3 10. We request that the government produce a complete copy of the diary, only seven pages

ew York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on beha

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-vork/ny- jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu- story.

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00101096 October 13, 2020 Page 3 10. We request that the government produce a complete copy of the diary, only seven pages

s Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

inal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-vork/nv- jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu- storv.

tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

he government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. EFTA00101104 October 13, 2020 Page 3 10. We request that the government produce a complete copy of the diary, only seven pages

s Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear ..,-:,w.cohenges

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo

han United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We write on behalf of our client, Ghislaine Maxwell, in opposition to the government's October 6, 2020 letter

er that the Materials pertain to individuals who claim to have been "sexually abused by [Jeffrey] Epstein" (id. at 2), but who have not accused Ms. Maxwell of participating in or facilitating that conduct in any way. Accordingly, the Materials identifying these witnesses and their prior statements are e

Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: We

saulted by Mr. Epstein, but has not alleged that Ms. Maxwell participated in, was involved in, or facilitated

nt with the government's theory of the case." United States v. Harris, No. 00 Cr. 105 (RPP), 2000 WL 1273720, at *2 (S.D.N.Y. Sept. 7, 2000) (citing Kyles v. Whitley, 514 U.S. 419 (1995). 2. Rule 16 Rule 16 provides, in pertinent part: Upon a defendant's request, the government must permit the defe

7 October 28, 2020 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) We write in response to your letter of October 13, 2020 setting forth "requests for discovery, inspection, and copying, in accord

th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) We write in response t

22 specific requests (the "Requests"). The letter also makes a general request for materials pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419 (1995), followed by 10 "specific Brady requests." As an initial matter, we take seriously our disclosure obligations, incl

o light. With respect to your requests under the section titled "Exculpatory Evidence," the Government is not aware of any evidence suggesting that Maxwell was not involved in or aware of the conduct alleged in the Indictment. The Government will provide timely disclosure if it learns of any such materi

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tober 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest,

s Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 800 Third Pianos

any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil c

and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings that took place in or about 2016 in which certain of the Attorney

reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search fo