EFTA00075841.pdf

GG 000 Thud Avenue New Yoek. NY 10022 COHEN & GRESSER LLP +1 212 957 7600 phone owswoohensresser corn Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com April 7, 2021 BY 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) Dear We write to renew our request that you produce the FBI case file concerning the investigation of We had originally asked for the file in our discovery request letter dated October 13, 2020. You denied our request for the file on October 28, 2020, stating that the file has "no relation to your client and has no bearing on the charges in this case." See 10/28/2020 Letter at 7. Now that the S2 supersedii.dictment has broadened the allegations against Ms. Maxwell up to in or about 2004, Mr. is very much relevant to the charges in this case and the file should be produced. For example, in your letter to defense counsel dated March 29, 2021, you specifically identified several Bates numbers which you say relate to the new accuser referenced in the indictment as Minor Victim-4. Those Bates numbers include messa e ads containing numerous n that we believe were taken by, and signed by, using the initials ese message pad slips appear to be some of only a handful of documents upon which the nil:e nt intends to rely to corroborate the testimony of Accuser-4. Furthermore, Mr. was discussed extensively at the February 29, 2016 meeting between AUS nd attorneys Brad Edwards, Stan Pottinger and Peter Skinner, where the attorneys pitched the government to open an investigation into Epstein and Maxwell. See SDNY_GM_02742882. The notes appear to reflect an explanation of Mr. conduct that formed the basis for his obstruction charge. See id. As you are aware, the discussions at the February 29, 2016 meeting are squarely at issue in Ms. Maxwell's motion to suppress. As such, the information contained in the FBI investigation file will be relevant at any hearing that takes place on Ms. Maxwell's motion and should therefore be produced. EFTA00075841 April 7, 2021 Page 2 Thank you in advance for your attention to these matters. Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP cc: Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi Sternheim, Esq. EFTA00075842