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Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page3of10 As previously detailed, Annie Farmer is believed to be the alleged victim referred to in the superseding indictment as “Minor Victim 2.” She is represented by BSF. See, e.g., Annie Farmer v. Indyke, et al., No. 19 Civ. 10475 (LGS). The proposed BSF Subpoena calls for production of particular physical items that belong to Annie Farmer, specifically a journal, black boots, and certain photographs. BSF produced photos of those items (and PDF replications of the photographs) to Ms. Maxwell in the Annie Farmer action. It is unknown whether the items are currently in the possession of BSF or Ms. Annie Farmer. Ms. Maxwell proposes to serve a subpoena, attached as Exhibit 1, on Ms. Annie Farmer for the physical items; counsel also proposes that service be effected through BSF if they are willing to accept service.' Inspection of each of these items in advance of trial is necessary for the reasons set forth in the Ms. Maxwell’s First Motion. Ms. Maxwell seeks also to serve a subpoena on Ms. Annie Farmer in the event that BSF claims the physical items are not in their custody or control, but rather belong to (and are in the possession of) their client. The proposed subpoena seeks no new or additional information beyond that which is sought by the BSF Subpoena. Similarly, Ms. Maxwell seeks also to serve a subpoena on Annie Farmer’s older sister, Maria Farmer. See Exhibit 2. Like Annie, Maria Farmer is represented by BSF. See Maria Farmer v. Indyke et al., 19 Civ. 10474 (NRB). Ms. Maxwell seeks to serve the proposed subpoena on Maria Farmer through BSF if they are willing to accept service. Defense counsel does not believe that Maria Farmer is mentioned in the Indictment, however, counsel believes the government will offer her as a witness at this criminal trial either ' Fed. R. Crim. P. 17(c)(3) requires notice to an alleged victim where “personal or confidential information about a victim” is being sought. These subpoenas are addressed directly to the alleged victims so notice should be provided upon issuance. DOJ-OGR-00005045