239 [DOJ-OGR-00003955—DOJ-OGR-00003960]

Case 1:20-cr-00330-PAE Document 239 _ Filed 04/23/21 Page1of6 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 April 23, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court’s Order dated April 16, 2021, which directed the Government to confirm that it has complied with its discovery obligations with respect to the non-prosecution agreement (“NPA”) between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida (“SDFL”). (Dkt. No. 207). A. Overview The Government takes its discovery and disclosure obligations seriously, and it has endeavored to take an expansive approach with respect to those obligations throughout the pendency of this case. In particular, the Government carefully formulated its discovery and disclosure plan in this case to ensure that it not only satisfies its Rule 16, Brady, Giglio, and Jencks Act obligations with respect to the materials already in the possession of the prosecution team, but that it also makes reasonable efforts to identify other potentially disclosable material within the files of other investigative agencies who are not part of this prosecution team. This approach was formulated in close consultation with multiple layers of supervisors within the U.S. Attorney’s Office for the Southern District of New York. The Government set forth its intentions with respect DOJ-OGR-00003955