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Case 1:20-cr-00330-PAE Document 247 _ Filed 04/23/21 Page14of17 The Honorable Alison J. Nathan April 5, 2021 Page 14 of 17 The Defendant has not explained how any of the photographs are relevant to her defense and would “help in establishing her innocence” or why “the dates of creation” or “other specifics” about these photographs are relevant to her defense. Resp. Ltr. at 11. VI. Request 12: EVCP Material A. The Request is Not Specific. The Defendant does not even address the lack of specificity of her Request for “any submission to the Epstein Victim’s Compensation Program made by You, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by You or Your Clients, and any compensation received by You or Your Clients.” This Request on its face includes a// claims that BSF has submitted on behalf of all of its clients, including all of the supporting documents (including sensitive medical and therapy records) that each client submitted with those claims. As BSF explained in its objections, the Defendant cannot merely request every piece of highly confidential information that BSF’s clients submitted to the Program in the hopes that something relevant and admissible turns up. The Defendant offered to narrow this Request to EVCP Material submitted on behalf of victims who ultimately testify in this action. This “narrowing” does not change the improper nature of Request 12—even the narrower request would call for broad swaths of material that are both irrelevant to the charges against the Defendant and that are highly sensitive in nature. B. The Defendant Has Not Demonstrated Relevance, Other Than Potential Impeachment. Request 12 independently fails because the Defendant seeks the EVCP Material only for impeach purposes. The Defendant argues that the EVCP Material is not “mere impeachment material” because it is also “Brady material.” Resp. Ltr. at 13. This argument does not make this Request proper under Rule 17. First, the Defendant does not explain how the EVCP Material is DOJ-OGR-00004014