EFTA00084863.txt

"evidence to be presented against Ms. Maxwell... within the possession, custody, or control of the government"

"We write on behalf of our client, Ghislaine Maxwell"

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

"we request that the government conduct an affirmative search... favorable to the defense as to either guilt or punishment... against Ms. Maxwell... Si"

"Christian R. Evercle11 [at] COHEN & GRESSER LLP... We write on behalf of our client, Ghislaine Maxwell"

"meetings... to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell"

"any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein"

"alleged that Ms. Maxwell participated in, was involved in, or facilitated the alleged sexual abuse"

"any other witness who has alleged that Ms. Maxwell engaged in or facilitated improper sexual conduct"

"any other witness who has alleged that Ms. Maxwell engaged in or facilitated improper sexual conduct"

"any other witness who has alleged that Ms. Maxwell engaged in or facilitated improper sexual conduct"

"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"