Epstein Secrets

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan:

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of April 27, 2021, r

, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan: The Go

ness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Maxwell. No. 20 Cr. 330 Dear Judge Nathan: We represent the independent, neutral administrator of the Epstein Victims' Compensation Program (the "EVCP").

is "otherwise procurable" or, indeed, already in Ms. Maxwell's possession. See United States v. Pena, No. 15

sentatives of the EVCP). As courts have held, such statements are not subject to subpoena, even when sought from a third party. See United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (quashing request under Rule 17(h) for materials that "likely constitut

New York, New York 10007 Re: United States v. Ghislaine Marvel!, S2 20 Cr. 330 (MN) Dear Judge Nathan:

ness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records