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Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page 2of10 Defendant Ghislaine Maxwell makes this second ex parte and in camera motion for the Court to enter an Order authorizing her counsel to issue additional subpoenas under Federal Rule of Criminal Procedure 17(c). The legal and factual grounds for this second motion are largely identical to those set forth in Ms. Maxwell’s first ex parte and in camera motion (“First Motion”) for issuance of a subpoena to the law firm Boies, Schiller and Flexner LLP (“BSF”), filed with the Court on February 21, 2021, and Ms. Maxwell expressly incorporates that First Motion by reference. Because additional subpoenas are necessary for (a) her pending pre-trial motions, and (b) in order to examine certain physical pieces of evidence in advance of trial in order to adequately prepare for trial, she hereby sets forth additional facts and argument pursuant to United States v. Nixon, 418 U.S. 683, 699-700 (1974), to justify these additional subpoenas. As with her First Motion, she makes this motion ex parte for the “strong policy reasons in favor of an ex parte” process and because she is providing detail regarding her investigative and trial strategy to demonstrate compliance with the specificity, relevance, and admissibility requirements of a Fed. R. Crim. P. 17 subpoena. United States v. Reyes, 162 F.R.D. 468, 470 (S.D.N.Y. 1995). I. The Additional Subpoenas Ms. Maxwell seeks to serve Rule 17 subpoenas on the following law firms and individuals. The subpoenas seek specific items each identified in their respective Attachment A: 1. Annie Farmer (Ex. 1) 2. Maria Farmer (Ex. 2) 3. Brad Edwards, Esq. of Edwards Pottinger (Ex. 3) 4. Stanley Pottinger, Esq. of Edwards Pottinger (Ex. 4) II. Annie and Maria Farmer Items 1-5 DOJ-OGR-00005044