EFTA00014671.pdf

"Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena... she also disclosed theories related to her defense, strategy, and work product"

"United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)"

"The Honorable Alison J. Nathan United States District Court Southern District of New York Re: ... United States v. Ghislaine Maxwell"

"She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund."

"Accuser-2 has been represented by BSF since approximately 2016."

"She claims to have kept a journal for a period in 1996 in which she described various events"

"participated in the Epstein Victim Compensation Fund"

"Accuser-2 relied on select portions of the journal in public discussions with various representatives of the media... The Daily Podcast, NY Times (Aug"

"Haddon, Morgan and Foreman... Jeffrey Paglluca"

"Jeffrey S. Pagliuca... Respectfully Submitted"

"The Honorable Alison J. Nathan May 12, 2021"

"The S2 indictment, paragraph 9(b), claims that Maxwell interacted with Accuser-2"

"Accuser-2's journal contains dated entries"

"having the FBI secure the boots"

"described various events, including her interactions with Jeffrey Epstein. ... support for her claims against Epstein."

"Given that Accuser-2, the putative witness, has publicly claimed to rely on the journal"

"at Epstein's residence in New Mexico"

"Maxwell interacted with [Accuser-2] on at least one occasion in or about 1996 at Epstein's residence in New Mexico"

"Accuser-2's journal from 1996 purports to document encounters with Epstein in New York."