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Case 1:20-cr-00330-PAE Document 244 _ Filed 04/23/21 Page2of14 The Honorable Alison J. Nathan April 2, 2021 Page 2 government witness in this case. Presumably, BSF is in communication with the government and knows which of their clients will testify. This narrowing language was offered to BSF but rejected during the Court ordered conferral. As to the rest of the items, BSF’s boiler-plate arguments fail for the reasons discussed below. Requests 1-5 BSF argues that Requests 1-5, communications between BSF and the government about Ms. Maxwell, are “overbroad and non-specific.” To advance this argument BSF carefully ignores the actual language of Requests 1-5 which are specific as to date and limited by the identified individuals and subject matter. Request 1 is for communications between BSF and the United States Attorney for the Southern District of New York (“USAO-SDNY’’) starting in 2015 about Ms. Maxwell including the meeting that former SDNY-AUSA-turned-BSF lawyer Peter Skinner (and others) had with then AUSA 3. Request 2 similarly narrowly requests communications regarding yy , an alleged witness against Maxwell being promoted by BSF to the government. Requests 3, 4, and 5 are for communications between BSF and lawyers Brad Edwards, Stanley Pottinger, and Paul Cassell about any meeting with the USAO-SDNY concerning Ghislaine Maxwell or 3g. This is no fishing expedition. The government admits that there were, in fact, meetings and communications between these individuals and the USAO-SDNY about Ms. Maxwell and Vc know that gg bad at least one in-person meeting (and possibly another) and that she communicated by email and telephone with Mr. Pottinger about yy ME Who was being proffered to the government as a witness against Ms. Maxwell. As these requests are narrowly limited by time, subject matter, and participants, it is disingenuous to argue that they fall into the disfavored “any and all” document subpoenas. In DOJ-OGR-00003973