HADDON MORGAN FOREMAN March 8, 2021 VIA 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) 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, r.c Laura A. Menninger ISO East 10th Avenue Denver, Colorado 80203 www.hMtlOw.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 w