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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 15 of16 defense because it is in the possession of a third party. (Opp. 187-88). Ms. Maxwell anticipates that the rest of the diary will contain exculpatory information and inconsistent statements. It is therefore critical that Ms. Maxwell be able to review the original diary and to test it to ensure it is authentic and written contemporaneously with the events it describes. If the government will not obtain the diary, the Court should order the government to disclose the author’s identity so that Ms. Maxwell can seek an appropriate subpoena.* CONCLUSION For the reasons set forth above, we respectfully request that the Court grant the motions presented in their entirety. Dated: March 15, 2021 New York, New York Respectfully submitted, /s/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell * The other documents that Ms. Maxwell has requested are relevant for her motions related to the Epstein Non- Prosecution Agreement and her suppression motions. (Dkt. 148 at 11). The Court should order the production of those documents for the reasons set forth in those motions. 12 DOJ-OGR- 00004242