Epstein Secrets

HADDON MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 1

fuse to produce the records; the records have previously been released to a news media outlet, "relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the government's "possession, custody, or control." We also request that your office detail when each batch of

uthern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pert

"relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the governm

Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity of the recipient of th

05 March 8, 2021 Page 2 Further, we request that you make inquiry of your "Prosecution Team," to include the USAO- SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce

ch 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 1

fuse to produce the records; the records have previously been released to a news media outlet, "relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the government's "possession, custody, or control." We also request that your office detail when each batch of

s Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pert

"relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the governm

Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity of the recipient of th

ntz March 8, 2021 Page 2 Further, we request that you make inquiry of your "Prosecution Team," to include the USAO- SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce

MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 1

fuse to produce the records; the records have previously been released to a news media outlet, "relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the government's "possession, custody, or control." We also request that your office detail when each batch of

"relate to" the investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the governm

Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity of the recipien

--- March 8, 2021 Page 2 Further, we request that you make inquiry of your "Prosecution Team," to include the USAO- SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce