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ng and Contacts with Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Seale
rmation at issue is peculiarly within the possession of the government (e.g., AUSA and AUSA la or others who are adverse to Maxwell (e.g., Boies, Edwards, Skinner, Pottinger). See Cortina, 630 F.2d at 1216 ("The violation here is particularly insidious because it is difficult to uncover misrepresentat
McCawlEya Pottinger, Brad Edwards, or Peter Skinner; and (2) did not interview anyone other than AUSA such as the other attendees of the meeting (Pottinger, Edwards, and Skinner), or any of the other AUSAs whom AUSA talked to about her contacts with attorneys. Most conspicuous, of course, is the government's
e Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim
016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At
records documenting the substance of the call. The Government has not identified any records that suggest AUSA- I ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
1) Doe No. 1. v. United States, 32, 104 33 86 749 F.3d 999 (11th Cir. 2014) 117, 118, 119 Dowling v. United States, 493 U.S. 342 (1990) 52 Edwards v. Mazzuca, No 00 Civ. 2290 (RIS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 155 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 34 Falter,
ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al
who participated in the February 2016 meeting. The Government is producing all identified emails to defense counsel today. 63 EFTA00095155 with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim
016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At t
r records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein
Entities connected to both Bradley Edwards and Pottinger, Edwards

Jeffrey Epstein
PERSONJane Doe
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSON
Lesley Groff
PERSONFBI
ORGANIZATION
David Boies
PERSON
Sarah Kellen
PERSON
Julie K. Brown
PERSON