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

rough the FOIA requests, the dates the documents were produced and the identity of the recipient 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

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

rough the FOIA requests, the dates the documents were produced and the identity of the recipient 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

rk S. Cohen Subject: Fwd: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER Good evening, In disregard of the Court's order, the team leader of Ms. Maxwell's security detail informed Ms. Maxwell that she will not have access to the laptop on Saturday. (See email below.) I will be notifying Judge Natha

access to her laptop on weekends and holidays. Please comply immediately. Thank you- Bobbi C. Stemheim, Esq. Docket Text: MEMO ENDORSEMENT as to Ghislaine Maxwell on 1115] LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated January 14, 2021 re: Laptop Access. ENDOR

dell )" ci "Mark S. Cohen" Subject: RE: URGENT-Ghislaine Maxwell 02879-509 - COURT ORDER Date: Fri, 15 Ja

isregard of the Court's order, the team leader of Ms. Maxwell's security detail informed Ms. Maxwell that she

xwell's security detail informed Ms. Maxwell that she will not have access to the laptop on Saturday. (See email below.) I will be notifying Judge Nathan of MDC's blatant disregard of the Court's order. Perhaps this will move the Court to direct Warden Tellez to appear and face questions concerning the