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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page1of25 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com joagliuca@hmflaw.com HADDON MORGAN FOREMAN November 22, 2021 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write in response to the motions to quash Ms. Maxwell’s Rule 17(c) subpoena to the Epstein Victims’ Compensation Program (EVCP). Four motions to quash were filed, one each by the government,! the administrator of the EVCP, Accuser-2, and Witness-3. Neither Accuser-1 nor Accuser-4 moved to quash. As explained below, the arguments against enforcement of Ms. Maxwell’s subpoena lack merit, and this Court should deny the motions to quash. FACTUAL BACKGROUND On November 15, this Court issued a Rule 17(c) subpoena to the EVCP at the request of Ms. Maxwell. The subpoena is narrow, specific, and targeted. It seeks just four categories of ' There is significant doubt whether the government has standing to move to quash, cither in its own capacity or on behalf of the accusers. See United States v. Nachamie, 91 F. Supp. 2d 552, 558-61 (S.D.N.Y. 2000) (recognizing a common “misunderstanding of the concept of standing to quash a Rule 17(c) subpoena” and concluding the government lacked standing to move to quash in its own capacity or on behalf of the third parties). Even so, because the administrator of the EVCP and two of the accusers moved to quash, Ms. Maxwell will respond to all the arguments made in opposition to her subpoena, even the government’s. DOJ-OGR-00011424