Case 1:20-cr-00330-PAE
Cy
HADDON
MORGAN
FOREMAN
April 2, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New York, NY 10007
Document 244
Filed 04/23/21 Page1of14
Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmflaw.com
[email protected]
Re: | Response to Letter Motion to Quash Rule 17 Subpoena to Boies Schiller Flexner LLP
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
Ms. Maxwell’s Rule 17 subpoena directed to Boies Schiller Flexner LLP (“BSF”) seeks
discrete sets of material relevant to legal issues before the Court now and relevant to the jury at
trial. Each item sought by the subpoena is identified with specificity and is admissible as
relevant evidence in this case. The Court should therefore deny BSF’s Motion to Quash
(“Motion”) (Dkt. No. 191) and direct BSF to comply with the subpoena with one narrowing
modification to Request 12, the Epstein Victim’s Compensation Program (“EVCP”) Material.
Ms. Maxwell agrees, based on BSF’s representations, that the subpoena should be narrowed at
this time in one respect. BSF proffered that they “submitted claims and supporting evidence to
the Epstein Victim’s Compensation Program on behalf of several Epstein survivors who have not
made separate claims against Maxwell.” Motion at 5. BSF acknowledged that that it represents
alleged victim 2 and potential trial witnesses Virginia Giuffre and Maria Farmer. /d. at 1,5. Ms.
Maxwell does not seek production of EVCP materials from any person who is not testifying as a
DOJ-OGR- 00003972