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Case 1:20-cr-00330-AJN Document 148 Filed 02/04/21 Page 15 of 23 C. Documents Related to Ms. Maxwell’s Motions Along with this motion, Ms. Maxwell has filed a motion to dismiss the indictment for breach of the Non-Prosecution Agreement entered into by Jeffrey Epstein and two motions to suppress the evidence obtained from the government’s subpoena of a. These motions request, as alternative relief, that the Court grant discovery and an evidentiary hearing on the issues bearing on the motions. Ms. Maxwell asked the government for documents relevant to these motions, but was denied. To the extent that the Court grants discovery related to these two motions, Ms. Maxwell requests, among other things, the documents requested in Exhibit E, which were previously requested from the government. (See Ex. E). Ms. Maxwell also requests the Court to order the government to produce a copy of the subpoena that it issued to a. As set forth in Ms. Maxwell’s motion to suppress, Maxwell was not aware that the subpoena had been issued and never had the opportunity to contest it. Ms. Maxwell seeks a copy of the subpoena to determine whether she has a basis to challenge it. Likewise, for the reasons set forth in her motion to suppress, Ms. Maxwell requests that the government produce copies of the other grand jury subpoenas issued in connection with this case for the production of Ms. Maxwell’s private and confidential records. ° III. Motion for Immediate Disclosure of Brady and Giglio Material Ms. Maxwell moves for an order, pursuant to Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, Kyles v. Whitley, 514 U.S. 419 (1995), United States v. Bagley, 473 U.S. 667 (1985), and Giglio v. United States, 405 U.S. 150 (1972) compelling the government to ° See Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government’s Subpoena iii and to Dismiss Counts Five and Six. 11 DOJ-OGR- 00002708