EFTA00011418.pdf

"We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material."

"Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell"

"Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007."

"criminal investigation into Mr. Epstein and Ms. Maxwell."

"Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016"

"2018, when the government asserts that it began the SDNY investigation into this case"

"82-page pros memo and 53-page indictment drafted as part of the investigation conducted by the Southern District of Florida"

"82-page pros memo... drafted as part of the investigation conducted by the Southern District of Florida"

"Ms. Maxwell... exculpate Ms. Maxwell of the offense alleged... grand jury that indicted this case"

"relevant to any possible defense or contention that Ms. Maxwell might assert"

"Christian R. Everdell COHEN & GRESSER LLP"

"COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York New York 10022"

"In the event that you are unable or unwilling to provide the information and documents requested in this letter, please advise us by October 21, 2020"

"cc: Mark S. Cohen, Esq."

"any other witness who has alleged that Ms. Maxwell engaged in or facilitated improper sexual conduct at any time up to the present"

"All financial records, including all records reflecting any payments or money transfers from Mr. Epstein or his associated businesses to these individ"

"meetings that took place in or about 2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation"

"meetings that took place in or about 2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation"

"alleged sexual abuse by Mr. Epstein or Ms. Maxwell... facilitated the alleged sexual abuse"

"FBI's case file regarding the investigation of for obstruction of justice"

"the witness's bias or hostility against Mr. Epstein or Ms. Maxwell"

"Pennsylvania v. Ritchie, 480 U.S. 39 (1987)"