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Case 1:20-cr-00330-PAE Document 247 Filed 04/23/21 Page8of17 The Honorable Alison J. Nathan April 5, 2021 Page 8 of 17 Requests themselves. Resp. Ltr. at 7. In Requests 3 through 5, the Defendant seeks all communications between BSF and its co-counsel in a civil litigation against Maxwell (Giuffre v. Maxwell, 15-cv-07433-LAP) “between 2015 and the date of this subpoena about any meeting with the United States Attorney concerning Ghislaine Maxwell or gg.” Certainly, some of these communications, if they exist, may fall under the work product umbrella if they were internal discussions with co-counsel. Moreover, BSF and its co-counsel have a common interest protection in their communications. The Defendant’s overbroad Requests make it impossible for BSF to determine how many responsive communications would be protected and why. Again, it is the Defendant’s burden to demonstrate that all of the communications she seeks would be relevant and admissible, and it is not BSF’s burden to review broad swaths of material to determine what the Defendant is entitled to under Rule 17. C. Communications Between BSF and the Government Are Procurable from the Government. Even if Requests 1 through 5 could overcome Nixon’s three hurdles, however, Requests 1 and 2 would still fail to the extent that they ask for communications with the Government, which the Defendant can procure from the Government. The Defendant admits that the Government has the communications she is seeking, but complains that the Government “has failed to produce, or even look for these communications and Ms. Maxwell has no other means to obtain them.” Resp. Ltr. at 8. In fact, this dispute is currently pending before the Court—the Defendant filed a Motion for a Bill of Particulars and Pretrial Disclosures in which she seeks an order compelling the Government to disclose the very communications with BSF she seeks in the Subpoena and to immediately disclose all Brady and Giglio materials. ECF Nos. 148, 148-5 (motion requesting documents relating to the Defendant’s two motions to suppress evidence obtained from what DOJ-OGR-00004008