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Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 11 of 23 government should be required, at a minimum, to remove this shroud of mystery and file a bill of particulars to permit Ms. Maxwell to prepare her defense and avoid unfair surprise at trial. Bortnovsky, 820 F.2d at 574. Accordingly, we request the particulars set forth in Exhibit A. (See Ex. A). II. Motion for Disclosure and Inspection of Documents Ms. Maxwell seeks an order directing the government to produce certain material believed to be in the possession of the government or its agents, or which could be obtained by the government from other prosecutor’s offices, law enforcement officers and investigators, witnesses, or persons having knowledge of the events giving rise to this case. Ms. Maxwell requested these documents from the government, but was denied. As discussed further below, Ms. Maxwell has good reason to believe that some of these documents contain exculpatory Brady material; hence, the government has a duty to produce them to the defense, and should be ordered to do so immediately. The alternative means of obtaining the requested documents would be through subpoenas served on the government and unidentified witnesses, which is an impractical pursuit. The government would likely move to quash any subpoena, requiring court intervention; and it would be impossible to serve subpoenas on witnesses without knowing their names and locations. We therefore request that the Court direct the government to produce the documents set forth below. A. Unredacted FBI 302 Reports and Notes of Interviews DOJ-OGR- 00002704