EFTA00017995.pdf

Type: pdf
Source set: data-set-8

Extracted text

HADDON
MORGAN
FOREMAN
March 8, 2021
VIA EMAIL
United States Attorney's Office
Southern District of New York
New York, NY 10007
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, e c
Laura A. Menninger
Denver Colorado 80203
www.hmflow.com
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
investigation and prosecution of Jeffrey Edward Epstein and relate to the investigation and
prosecution of Ghislaine Maxwell. We perceive no legal basis for you to refuse to produce
the records; the records have previously been released to a news media outlet, "relate to" the
investigation and prosecution of Ms. Maxwell's alleged co-conspirator, and are in the
government's "possession, custody, or control."
We also request that your office detail when each batch of documents, by Bates number or
some other identifier, were released to Radar Online. The public availability of, for example,
witness statements and other investigative materials is relevant to this case because we believe
there have been efforts by certain witnesses to conform their testimony to the public
statements and police reports made by other witnesses. It is relevant and material to Ms.
Maxwell's defense to know when the FBI made any such witness statements …

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