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NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
axwell, 20 Cr. 330 (AJN) Dear ..,-:,w.cohengessercom We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
ed States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
ed States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
ed States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
NY 10022 ♦1 212 957 7600 phono www colsmipossoo corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following request
Page: EFTA00011418 →ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other
Page: EFTA00011420 →rors, witnesses under examination, court reporters, and attorneys from the United States Department of Justice. Consistent with the requirements of Brady v. Maryland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the g
Page: EFTA00011422 →Entities connected to both Brady and the Epstein Victims' Compensation Program

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
Southern District of New York
ORGANIZATION
Paul Cassell
PERSONJane Doe
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSON
David Boies
PERSON
Marc Rich
PERSON
Colorado
LOCATIONSigrid McCawley
PERSONCohen & Gresser LLP
ORGANIZATION
Alfredo Rodriguez
PERSON
Bagley
PERSON
Virginia Giuffre
PERSONLaura Menninger
PERSON