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Ghislaine Maxwell's defense team files a motion requesting the court to authorize subpoenas to Annie...

Ghislaine Maxwell's defense team files a motion requesting the court to authorize subpoenas to Annie Farmer, Maria Farmer, Brad Edwards, and Stanley Pottinger for specific evidence related to the allegations. The motion is made ex parte and in camera, citing policy reasons and the need to protect investigative and trial strategy.

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

Florida Office

Cr 1) '.1.d Florida Office Bradley J. Edwards *Ol Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing EDWARDS POTTINGER LLC October 21, 2020 FOIA PRIVACY EXEMPTION VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorney 86 Chambers Street, Third Floor New York. New York 10007 Dear New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in I>istrict of Columbia • Admitted m Florida t Admitted in New York Beard (:crtified Civil Trial lau)rr Re: Re tuest for Tangible and Documentary Evidence (Touhy Request) Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07773 Victim: In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relatin

EFTA00023053

Florida Office

ir" Crd Florida Office Bradley J. Edwards *Ol Seth M. Lehrman 't Brittany N. Henderson *0 Matthew D. Weissing VIA E-MAIL AND FEDEX The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York Assistant United States Attorne EDWARDS POTTINGER LLC October 15, 2020 New York Office J. Stanley Pottinger j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York Hoard Ccitified Civil Trial LAWFT Re: Request for Tangible and Documentary Evidence (Touhy Request) Katlyn Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07771 Dear Mr. Kochevar: In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Katlyn Doe.' Se

Court Filing Exhibit: 285-1

This court filing exhibit contains notes and summaries of Virginia Roberts' testimony and experiences with Jeffrey Epstein and Ghislaine Maxwell, detailing their sex trafficking operation and abuse of minors. The document highlights the involvement of various individuals and law enforcement agencies in the investigation and prosecution of Epstein. It provides new insights into the case and potentially significant evidence.