Epstein Secrets

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (S.D.N.Y. Sept. 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.

4 Table of Exhibits EXHIBIT J: Notes of Feb. II, 2021 Call with AUSA (Sealed) EXHIBIT K: Handwritten Notes by AUSA of Meeting 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

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

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

ons between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14

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

al communications between the government and the attorneys for these individuals — including , but not limited to, , David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. 14. We request

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

ses Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (.=. Sept 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Marcel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 19

-- Table of Exhibits EXHIBIT J: Notes of Feb. II, 2021 Call with AUSA (Sealed) EXHIBIT K: Handwritten Notes by AUSA of Meeting 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