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considers unfavorable to Ms. Maxwell, begrudgingly EFTA00014671 --- PAGE BREAK --- The Honorable Alison J. Nathan May 12, 2021 Page 2 produce Brady material with various disclaimers such as "although the government is not obligated to do so" (Dkt. 269 pp. 8, 9), and obfuscate the importance of l
Page: EFTA00014672 →cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
Page: EFTA00014672 →ompensation payments and application for and receipt of emergency victim compensation payments may well have been 'favorable' within the meaning of Brady," requiring government disclosure of exculpatory evidence to criminal defendants); payments and promises made to cooperating witnesses. See also, Un
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
ompensation payments and application for and receipt of emergency victim compensation payments may well have been 'favorable' within the meaning of Brady," requiring government disclosure of exculpatory evidence to criminal defendants); payments and promises made to cooperating witnesses. See also, Un
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
ccept information it considers unfavorable to Ms. Maxwell, begrudgingly EFTA00096510 The Honorable Alison J. Nathan May 12, 2021 Page 2 produce Brady material with various disclaimers such as "although the government is not obligated to do so" (Dkt. 269 pp. 8, 9), and obfuscate the importance of l
cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
Entities connected to both Brady and the Epstein Victim Compensation Fund

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSON
David Boies
PERSON
Colorado
LOCATION
Cynthia Nixon
PERSONCohen & Gresser LLP
ORGANIZATION
Denver
LOCATION
Alaska
LOCATION
Bagley
PERSONBobbi C. Sternheim
PERSONJack Scarola
PERSONDarren Indyke
PERSONMORGAN & FOREMAN
ORGANIZATION
Kentucky
LOCATIONBilzerian
PERSON
Michael Barker
PERSONOffice of the District
ORGANIZATION