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Case 1:20-cr-00330-PAE Document 247 _ Filed 04/23/21 Page11of17 The Honorable Alison J. Nathan April 5, 2021 Page 11 of 17 No. 138 at 2 n.2. Again, however, the Defendant does not explain why Maria Farmer’s engagement letter with BSF is relevant to support this proposition or is otherwise relevant to the motion. The Defendant’s conclusory arguments that the engagement letters between BSF and the Farmers are relevant to something other impeachment are unpersuasive and demonstrate that she cannot clear Nixon’s relevance hurdle as to Requests 6 and 7. II. Request 8: Grand Jury Subpoena to BSF Request 8 fails for the same reason that Requests 1 and 2 fail. If the Defendant is entitled to this information, then she must obtain it from the Government. And if she is not entitled to this information, she cannot use Rule 17 to circumvent Rule 16’s limitations. See supra Part I.C. IV. Request 9: Annie Farmer’s Journal® As to the Defendant’s request for an original copy of Annie Farmer’s entire journal from when she was a teenager, the Defendant contends that the journal is exculpatory because the relevant passages do not mention the Defendant—but this is information that she already has, and she does not explain why she needs the entire journal prior to trial if she already has the allegedly exculpatory information in the journal. The Defendant already has copies of all of the relevant pages of the journal. She does not explain why she needs to inspect the entire journal “to establish whether the journal is authentic and complete and whether or not spoliation has occurred.” Resp. Ltr. at 9. This purported need to inspect the journal for authenticity would carry more weight if the journal was inculpatory, and thus she sought to examine the authenticity of the pages containing allegations against her, but she contends it is instead exculpatory. If the Defendant seriously contends that the journal is relevant because it is exculpatory, and that it is exculpatory because ° BSF also points the Court to the objections that Ms. Farmer has herself posed in response to the Defendant’s proposed Rule 17 subpoena to her, in which the Defendant requests the same journal from Ms. Farmer. DOJ-OGR-00004011