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Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page5of10 Nixon Factors: Each of the items specified in the Annie and Maria Farmer proposed subpoenas is relevant, specific and admissible. These two alleged victims have publicly identified the materials and publicly proclaimed they corroborate and support their allegations. There are no evidentiary impediments to admissibility. The documents, photographs, footwear, envelope and mementos presumably can be authenticated by Annie or Maria Farmer at trial. To the extent that the items turn out to have been altered or do not exist the absence of this evidence is also relevant and admissible at trial as exculpatory evidence. II. Brad Edwards and Stan Pottinger Items 1-5: Communications Concerning Meetings with the U.S. Attorney’s Office As detailed in the First Motion, Brad Edwards and Stan Pottinger’ represented Virginia Giuffre (along with BSF) beginning in or about 2015. It was in connection with that representation that both attorneys apparently met with AUSA Amanda Kramer on or about February 29, 2016 in order to press a criminal prosecution of Ghislaine Maxwell. See First Motion at 4-9. Based on the discovery recently produced, Mr. Pottinger is known to have emailed with Ms. Kramer in or about May 2016. According to a “source,” the NY Daily News reported that “Boies and Pottinger re-approached Kramer [after Ms. Maxwell’s July 2016 deposition] and asked if the Southern District would consider charging Maxwell with perjury.” AUSA Kramer has claimed that she does not “remember” a second meeting. Mr. Edwards wrote about his first meeting with the U.S. Attorney’s Office in his memoir, Relentless Pursuit. 3 In 2015-17, Mr. Pottinger and Mr. Edwards worked at different law firms. At some unknown later time, they joined efforts and formed their current firm, Edwards Pottinger. It is unclear who the current custodian of their records might be, so Ms. Maxwell proposes serving subpoenas on both of them individually. DOJ-OGR-00005047