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burn, We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2, to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents. As the Court will recall, this is a case in which the plaintiff,M has alleged that she was sexually trafficked by
this is a case in which the plaintiff,M has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four defendants who did not invoke her Fifth Amendment right against self-incrimination to refuse to produce docume
ts. But in response to requests for production, Ms. Maxwell produced very little information. Following that
stein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four def
ue" may be an element of the cause of action that has to prove at trial. Of course, tax returns frequently reflect "things of value." Employee or Business Records Associated with Jeffrey Epstein has asked Ms. Maxwell to produce "[41 documents relating to any employee lists or records associated with you, Jeff
the United States TO: The Central Authority of the United Kingdom SUBJECT: Request for Assistance in the Matter of the Prosecution of Chislaine Maxwell DATE: August=a, 2021 The Central Authority of the United States of America ("U.S.") requests the assistance of the Central Authority of the Unite
deral Bureau of' Investigation (collectively the "U.S. authorities") are prosecuting charges of violations of United States criminal law concerning Ghislaine Maxwell and her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to and including at
odd.assj. TIME CONSTRAINTS Please A...[ [Ls totem end execute this request it-on an expedited basis. Trial in the prosecution of United States v. Ghislaine Mama is scheduled to begin on November 29, 2021, with production of evidence required in advance of trial. Accordingly, the U.S. authorities seek t
s. 6 EFTA00085206 Citizenship: U.S. Name: Date of Birth: 04 March 1977 Place of Birth: United Kingdom Citizenship: UK ASSISTANCE NEEDED Business Records BFitrish-ftipitwys Pleoservide-oll-treeown-iftleFliffill0R-ffltd-trovelnveetirds-feetn-Britielfrrtipextyrriev-the following-individuate.; •—alker
d Assistance in the Matter of the Prosecution of Ghislaine Maxwell DATE: August 4, 2021 The Central Autho
the United States TO: The Central Authority of the United Kingdom SUBJECT: Request for Expedited Assistance in the Matter of the Prosecution of Ghislaine Maxwell DATE: August 4, 2021 The Central Authority of the United States of America ("U.S.") requests the assistance of the Central Authority of the Unite
uest is sensitive in that it recounts specifics and evidentiary detail that may not be known, the exposure of which could impede the prosecution of Maxwell, and the U.S. authorities' related ongoing investigation. Premature notification of the existence of this request could jeopardize the investigation
at occurred prior to that time, the penalties would be lower and may not include mandatory minimum sentences. 6 EFTA00093030 ASSISTANCE NEEDED Business Records Please provide records demonstrating the enrollment and attendance of between approximately 1994 and 1995. Please provide records demonstrating
tion without consulting the school's attorneys. Ms. Stein accepted service of the Grand Jury subpoena, the Appearance Notice, the Certification of Business Records and Appendix A, (Document Inventory). She stated that she would consult the school's attorneys, then contact SA at the telephone number provided on
Page: EFTA02857863_p35 →mi Attn: SSA From: Miami Squad PB-2, PBCRA Contact: SA pproved By: Drafted By: :enk Case ID #: 31E-MM-108062 Title: CHANGED JEFFREY EPSTEIN; GHISLAINE N. MAXWELL WSTA - CHILD PROSTITUTION Synopsis: To request assignment of co-case agent and submit documents to case file. Previous Title: Title marked "
Page: EFTA02857863_p55 →ntacted 's mother in Phoenix to arrange a trip for to fly to Epstein's ranch in New Mexico. was under the impression the trip was for Epstein and Maxwell to get to know her better and finalize her summer plans for traveling to Thailand. Originally, was going to accompany to New Mexico; however, Ep
Page: EFTA02857863_p67 →Entities connected to both Ghislaine Maxwell and Business Records

Jeffrey Epstein
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONthe Southern District
LOCATION
New York
LOCATIONFBI
ORGANIZATION
Jean-Luc Brunel
PERSON
United Kingdom
LOCATION
the United States District Court
ORGANIZATION
Foley Square
LOCATIONCriminal Division
ORGANIZATION
Force
ORGANIZATIONThe Central Authority
ORGANIZATIONSBU -LAW ENFORCEMENT
ORGANIZATIONTravel/Border Records
ORGANIZATIONThe Superseding Indictment
PERSON