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Case 1:20-cr-00330-PAE Document 247 _ Filed 04/23/21 Page10of17 The Honorable Alison J. Nathan April 5, 2021 Page 10 of 17 Il. Requests 6 and 7: Engagement Letters The Defendant provides no explanation at all as to how engagement agreements between BSF and Annie and Maria Farmer would be relevant and admissible at trial, and thus cannot clear the Nixon hurdles. She states in a conclusory manner that “[t]he scope and dates of these engagements are relevant to Ms. Maxwell’s pending motions” and that “these agreements are exculpatory evidence.” Resp. Ltr. at 8. But it is entirely unclear how the fact that the Farmers are represented by BSF and the dates of the engagement letter could possibly be exculpatory, and the Defendant does not attempt to explain that proposition. Nor are the engagement letters relevant to any of the Defendant’s pretrial motions. The Defendant’s motions to suppress appear to be based on a theory that the Government improperly obtained evidence from BSF while it was representing Virginia Giuffre (not the Farmers) in Giuffre v. Maxwell. ECF Nos. 134, 140. The only relevance of Annie Farmer to the Defendant’s motion for dismissal based on pre-indictment delay appears to be based on Maxwell’s statement that Ms. Farmer was interviewed by the FBI in 2006. ECF No. 138 at 2. But the Defendant has not explained how an engagement letter between Annie Farmer and BSF is of any consequence to her theory. The Defendant also points out in her motion for dismissal based on pre-indictment delay that Annie Farmer may have cooperated with the Government in the criminal investigation of her abuser—an unremarkable proposition. /d. at 18. Not only is it unclear how this theory supports the Defendant’s arguments about pre-indictment delay, but the Defendant again has not explained how an engagement letter with BSF is relevant to this theory. As to Maria Farmer, she is only relevant to the motion for dismissal based on pre-indictment delay insofar as the Defendant argues that the Government knew about the allegations against the Defendant when Maria Farmer reported them to the NYPD years ago. ECF DOJ-OGR-00004010