EFTA00029458

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. 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 000 Thud Avenue New Yoek. 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 requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

EFTA Document EFTA01684300

EFTA00023053

[REDACTED - Survivor] Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition [REDACTED - Survivor] 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

[REDACTED - Survivor] v. Alan Dershowitz – Allegations of Sex Trafficking, NPA Manipulation, and Defamation

The complaint provides a dense web of alleged connections between Alan Dershowitz, Jeffrey Epstein, former U.S. Attorney Alexander Acosta, and the 2008 non‑prosecution agreement (NPA). It cites specif Roberts alleges she was trafficked by Epstein from 2000‑2002 and forced to have sex with Dershowitz. Dershowitz is accused of helping draft and pressure the government into the 2008 NPA that shielded

Filing # 38774829 E-Filed 03/08/2016 07:20:19 PM