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Case 1:20-cr-00330-PAE Document 244 Cy HADDON MORGAN FOREMAN April 2, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Souther District of New York 40 Foley Square New York, NY 10007 Filed 04/23/21 Page1of14 Haddon, Morgan and Foreman, P.c Jeffrey Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmflaw.com jpagliuca@hmilaw.com Re: — Response to Letter Motion to Quash Rule 17 Subpoena to Boies Schiller Flexner LLP United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Ms. Maxwell’s Rule 17 subpoena directed to Boies Schiller Flexner LLP (“BSF”) seeks discrete sets of material relevant to legal issues before the Court now and relevant to the jury at trial. Each item sought by the subpoena is identified with specificity and is admissible as relevant evidence in this case. The Court should therefore deny BSF’s Motion to Quash (“Motion”) (Dkt. No. 191) and direct BSF to comply with the subpoena with one narrowing modification to Request 12, the Epstein Victim’s Compensation Program (“EVCP”) Material. Ms. Maxwell agrees, based on BSF’s representations, that the subpoena should be narrowed at this time in one respect. BSF proffered that they “submitted claims and supporting evidence to the Epstein Victim’s Compensation Program on behalf of several Epstein survivors who have not made separate claims against Maxwell.” Motion at 5. BSF acknowledged that that it represents alleged victim 2 and potential trial witnesses Virginia Giuffre and Maria Farmer. /d. at 1,5. Ms. Maxwell does not seek production of EVCP materials from any person who is not testifying as a DOJ-OGR- 00003972