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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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
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
t have already been disclosed. 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence
Entities connected to both Ghislaine Maxwell and Fed R. Crim

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONLaura Menninger
PERSON
David Boies
PERSONSigrid McCawley
PERSON
Alfredo Rodriguez
PERSON
Christian Everdell
PERSON
Paul Cassell
PERSONCohen & Gresser LLP
ORGANIZATION
Southern District of New York
ORGANIZATIONBates
PERSONMark S. Cohen
PERSONJack Scarola
PERSON
New York Daily News
ORGANIZATIONSpencer Kuvin
PERSON