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Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page /7 of 10 Re =3Now BE claims she was abused by Epstein and Maxwell, 1 es Sec Indictment { 7(0): ee e—CSCSCSC‘B ES. Ms. Maxwell seeks any notes of Mr. Edwards or Mr. Pottinger’s communications with ggg or her counsel® because of their obvious exculpatory value and in order to authenticate them prior to trial. As described above, Mr. Edwards and Mr. Pottinger both met with Maria Farmer, sister of alleged victim-2 Annie Farmer, in or about June 2016, and purportedly were provided access to physical evidence documenting the Farmers’ claims. Ms. Maxwell seeks to inspect any such physical evidence in advance of trial, as well as their notes of those meetings, in order to test the authenticity of the materials and to rebut it. With regard to their clients, SM and Ms. Giuffre, the proposed subpoena seeks any physical evidence in Mr. Edwards and Mr. Pottinger’s possession and any non- privileged notes of their interactions. [nn LS Finally, Mr. Edwards and Mr. Pottinger have publicly identified themselves as having participated in the crafting of the Epstein Victims Compensation Program and representing some women in submissions to that program, including yy. Nixon Factors As to Items 1-5, we know that these lawyers communicated with SDNY Assistant U.S. Attorneys; the time frame is definite, 2015 to present, and the requests are limited to a discrete °In the notes of the meeting with Ms. Kramer, it appears that I was then represented by attorney a. DOJ-OGR-00005049