(USANYS)"

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

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 1 of 21

EFTA00032751

EFTA00023053

EFTA00144597

From To EFTA00144597 Subject: [EXTERNAL EMAIL] - Sweet Dreams... Date: Tue, 26 Nov 2024 06:07:08 +0000 Importance: Normal David Boies, Sergey Brin, Alan Dershowitz, Sigrid, Paul Cassell, Brad, Brittany, Stan, Goria and all involved in aiding and abetting, obstructing justice, rape and sex trafficking, including the media... GOTTCHA! CHECKMATE MOTHERFUCKERS, OR SHOULD I SAY KIDDIE FUCKERS! Hey Sergey? It gives me so much satisfaction knowing that most of you are sleeping soundly when I'm coming for every single one of you, and I mean every single one of you, and yes, that does include "journalists" and judges! I'M COMING .... SWEET DREAMS. Sent with Proton Mail secure email. On Monday, 4 November 2024 at 19:48, Dear Alina, wrote: We have never communicated, and I've never asked anything of you, but when the elections are over, can you please help file class actions on behalf of myself and ALL the Epstein against the Daily Mail, The Guardian, and every other British ne

Confidential

Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, -against- GHISLAINE MAXWELL, Defendant. Case No.: 15-cv-07433-RWS **CONFIDENTIAL** x Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAG NA 0 LEGAL SERVICES EFTA00083933 Confidential Page 2 1 2 APPEARANCES: 3 On Behalf of the Plaintiff: 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street 5 Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE 6 7 8 BY: BOIES SCHILLER & FLEXNER,LLP Fort Lauderdale, Florida 33301 MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE 9 SANDRA PER