EFTA00011418

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COHEN & GRESSER LLP October 13, 2020 BY EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 800 Third Pianos New York, NY 10022 ♦1 212 957 7600 phono www colsmipossoo corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of October 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest, which you produced on August 21, 2020. Fed. R. Crim. P. 16(a)(1)(A), (B). 2. We request that the government disclose and identify any statements of alleged co- conspirators that it intends to introduce at trial. 3. We request any prior criminal records of Ms. Maxwell. F