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Case 1:20-cr-00330-PAE Document 239 _ Filed 04/23/21 Page5of6 Page 5 With respect to Attorney-1’s inbox, the Government previewed in its October 7, 2020 letter that it planned to review the inbox—which is voluminous’—using search terms to identify witness statements and Giglio material. Those search terms did not include search terms relevant to the NPA, and the Government has not searched Attorney-1’s inbox for communications relating to the NPA. Instead, because the Government obtained these materials with an eye towards identifying any additional witness statements or Giglio material that might not otherwise be contained in the FBI Florida File, the Government ran search terms specific to this case, focusing on the names of victims, Government witnesses, and Ghislaine Maxwell. The Government’s review of the emails responsive to its search terms remains ongoing, and the Government will produce any non- duplicative documents that warrant disclosure. The Government expects this to be a limited set of documents that will be produced along with other Jencks Act and Giglio material. Of course, should the Government identify any exculpatory material during this review, including with respect to the NPA, it will promptly produce such material. As the foregoing illustrates, the Government has taken an expansive approach to discovery and is close to completing its review of files from other agencies for Jencks Act and Giglio material. Thus far, the Government has not identified potential Brady material with respect to the NPA during its review. To the extent the Government identifies potential Brady material with respect to the NPA, that is, material that supports Maxwell’s reading of the NPA as discussed above, or any other exculpatory material, the Government will promptly produce it. However, > More specifically, it appears that OPR obtained an entire snapshot of Attorney-1’s inbox, spanning several years, and encompassing all of Attorney-1’s emails during that time period. In other words, the inbox is not specific to the Epstein investigation, and it contains a high volume of communications relating to other cases and other internal SDFL matters. The snapshot provided by OPR contains emails and their attachments, both inbound and outbound, totaling more than 300,000 documents. DOJ-OGR-00003959