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Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page8of10 topic, communications about Ms. Maxwell, and ms’ The communications are relevant, authentic, and an appropriate evidentiary foundation can be established under many rules of evidence including F.R.E. 803(6). Ms. Maxwell seeks to introduce this evidence in connection with the pending motions. However, the information may also be admissible at any trial. Ms. Maxwell was the target of these lawyers who sought to profit by suing her and Epstein. Having Ms. Maxwell indicted during the pendency of the defamation action would have been very helpful to their cause. The lawyers also represent two of the accusers and many of the potential witnesses. The lawyers, and their clients, have traded information for years which has either, intentionally or unintentionally, allowed the witnesses to conform their testimony. Establishing the relationships between the witnesses, their lawyers, and the government will be a significant aspect of Ms. Maxwell’s defense. Additionally, there is reason to believe the government will attempt to call one or more of the lawyers to testify at trial to attempt to establish the materiality of Ms. Maxwell’s deposition testimony to the Giuffre civil action. With respect to the physical evidence (Items 6-9), each of the items specified is relevant, specific and admissible. Brad Edwards has described his and Mr. Pottinger’s meeting with Me bere are no evidentiary impediments to admissibility. The documents and photographs presumably can be authenticated by Annie or Maria Farmer at trial. To the extent 'The government’s recent disclosures concerning Ms. Kramer’s communications with Mr. Pottinger in May 2016 included an email from ggg that contained a screenshot of a new witness, as DOJ-OGR-00005050