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Case 1:20-cr-00330-PAE Document 252 Filed 04/27/21 Page6of9 jury subpoena at issue in Request 8; she thus contends that the absence of the documents in that production suggests coordination between the Government and BSF. Other than through conclusory speculation, she fails to explain how the contents of those letters may be relevant to her theory of preexisting coordination between the Government and BSF. Furthermore, to the extent Maxwell argues that the Government may have the documents and has refused to produce them in contravention of Brady or Giglio, the argument is little more than an attempt to circumvent the discovery processes that are in place. The production of Giglio material has not yet happened, and so any claim that the Government has failed to produce these documents consistent with its Giglio obligations is premature. Furthermore, as set forth in the Opinion & Order resolving some of Maxwell’s pre-trial motions, the Government has represented in good faith that it is cognizant of its Brady obligations and that it has complied and will continue to comply with them. This Court knows well that the Government has not always lived up to those obligations in every case. But nothing has transpired that provides any reason to doubt the good faith representations that have been made to the Court by the AUSAs appearing here. In sum, none of Maxwell’s theories justify production of these documents under the Rule 17(c) process. Request 12, which seeks “any” submission to the Epstein Victims’ Compensation Program made by BSF, fails under the relevance prong of the Nixon standard. The request seeks “any” submission made by BSF to the EVCP. In its reply brief, BSF represents that Maxwell offered to narrow this request to just those materials submitted on behalf of victims who ultimately testify in this action. The request’s failure to satisfy the Nixon standard is in part due to its relative lack of specificity, for even if Maxwell had established the relevance of some evidence captured by this request, she plainly has not demonstrated the relevance of all materials submitted to the EVCP. DOJ-OGR-00004044