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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G

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

diced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. G