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

of the documents. Finally, in your letter to Judge Nathan of October 7, 2020, you represented that your "Prosecution Team ... had no involvement in the Florida Investigation." (Dkt. 63 at 4.) You defined your "Prosecution Team" to include not only of the USAO-SDNY but also the FBI- New York Office. We believe that the FB

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

of the documents. Finally, in your letter to Judge Nathan of October 7, 2020, you represented that your "Prosecution Team ... had no involvement in the Florida Investigation." (Dkt. 63 at 4.) You defined your "Prosecution Team" to include not only of the USAO-SDNY but also the FBI- New York Office. We believe that the FB

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the defense letter dated October 23, 2020 in t

, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

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

ions from those files. By contrast, and as explained more fully in the Government's October 7 letter, this Prosecution Team—which played no role in the Florida Investigation—had not, prior to August 2020, received the materials identified in that letter from other prosecutor's offices. The Government has now obtained th