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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page2of25 The Honorable Alison J. Nathan November 22, 2021 Page 2 documents, all known to exist and all relevant and admissible in support of Ms. Maxwell’s constitutional rights to present a defense and to confront her accusers—Accuser-1, Accuser-2, Witness-3, and Accuser-4. Each of these individuals (the accusers) filed claims with the EVCP, and each received multi-million-dollar payouts. Accuser-1 has told the government that she received $5,000,000; Accuser-2 has told the government that she received $1,500,000; Witness-3 has told the government that she received $3,250,000; and Accuser-4 has told the government she received $3,500,000. Ms. Maxwell, however, does not have the payment records and cannot verify whether these figures are accurate. Nor does she have all the releases the accusers signed, and therefore no way to evaluate what consideration was offered and what the accusers gave up in exchange for the payouts. Finally, Ms. Maxwell does not have the accusers’ submissions to the EVCP or communications between the accusers and the EVCP. As a result, and even though the accusers’ claims were based in part on the same conduct Ms. Maxwell is now criminally charged with committing, Ms. Maxwell does not know how the accusers explained their entitlement to compensation from the EVCP and how, if at all, they alleged Ms. Maxwell was involved in the abuse. Left in the dark about these critical issues, Ms. Maxwell requested a subpoena to the EVCP seeking production of: (1) Any and all EVCP material submitted by each accuser, not limited to claims forms and supporting submissions made by each accuser. (2) Communications between the EVCP to each of the accusers and/or their attorneys; (3) Copies of any payments to the accusers and their attorneys; and DOJ-OGR-00011425