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

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 for, locate, i

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

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 for, locate, i

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

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 for, locate, i

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

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 for, locate, i

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

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 for, locate, i

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

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 for, locate, i

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

fic 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, including those

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

Pot and Kettle, LLC Certificate of Formation and Certificate of Conversion AND Pot and Kettle Assignment of Limited Partnership Interest (signed by Ghislaine and Duke of York) 6. Dispute with Diandra Douglas 358 El Brillo Way. Palm Beach 1. Proposal for new Generator for PB house GRM#004740716 Corresp

original signed and copies) 10. Correspondence Ghislaine Maxwell & 65th Street I. Jury Duty 2. Sotheby's Brokera

igned and copies) 10. Correspondence Ghislaine Maxwell & 65th Street I. Jury Duty 2. Sotheby's Brokera

& II BACKUP BINDERS PALM BEACH LITIGATION -Non-Prosecution Agreement and Addendum -June 12, 2008 Draft DOJ Letter -Letter to Filip from Starr and Whitley (5-27-08) -March 28, 2008 Letter to DOJ -DOJ Submission (Summary) -DOJ Submission (Attachment Letter) EFTA00300514 -April 8, 2009 Submission to

rations (Feb.23, 2010);Cert. of Amendment of Air Ghislaine to Shmitka Air;Certificate of Amendment of Certif

RCH FOURTH DRAWER: PALM BEACH LITIGATION -Non-Prosecution Agreement and Addendum -June 12, 2008 Draft DOJ Letter -Letter to Filip from Starr and Whitley (5-27-08) -March 28, 2008 Letter to DOJ -DOJ Submission (Summary) -DOJ Submission (Attachment Letter) -April 8, 2009 Submission to Hon. Mandelker

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

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 for, locate, i