HADDON

HADDON MORGAN FOREMAN March 8, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 16. Haddon, Morgan and Foreman, r c Laura A. Menninger N Under Rule 16(a)(1)(E), I ask that you provide to us the documents produced by the FBI to news media, as described in Radar Online v. FBI, 17 Civ. 3956 (PGG). The FBI in New York released to Radar Online some 1,232 pages "relating to the FBI's investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter signed by your office, 181 pages were released in full and 1,051 were released with partial redactions. Id. at 2. Your office made these representations and therefore presumably is aware of the documents' existence and constructively aware that their contents relate to the FBI invest