DOJ-OGR-00005117.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page5of21
ATTACHMENT A
DEFINITIONS
“You” or “Your” means Maria Farmer.
“Envelopes” means the envelopes that You described in a podcast with Whitney Webb that
aired on May 26, 2020 that You claimed “still have the touch DNA and fingerprints on them”
of “Jeffrey and Ghislaine” and that you offered to the FBI but the FBI said “we don’t need
it.” https://soundcloud.com/user-414392239/271-epstein-victim-maria-farmer-speaks-part-2-
the-last-american-vagabond-whitney-webb.
99 66
“Physical Evidence” means the “hundreds of photographs,” “old diaries,” “telephone books,”
“Rolodexes,” and “mementos . . . collected from [Your] time with Epstein and Maxwell” that
You showed to Brad Edwards and/or Stanley Pottinger at Your Paducah, KY home in June
2016, as described in excerpts from Relentless Pursuit, attached as Exhibit A.
“Contingent Fee Agreement or Engagement Agreement” means any writing describing the
terms that You agreed to for legal services from any attorney as required by New York Rule
of Professional Conduct 1.15 and 22 N.Y.C.R.R. Part 1215.
“EVCP Material” refers to any submission to the Epstein Victim’s Compensation Program
made by You, any releases signed by You and/or the Epstein Victim’s Compensation
Program, and any compensation received by You. The EVCP is described in Exhibit B.
INSTRUCTIONS
. Production of documents and items requested herein shall be made no later than April 1,
2021, at 1:00 p.m. Except for the originals of the “Envelopes” and “Physical Evidence,” you
may provide the records electronically by that date and time to Jeffrey S. Pagliuca or by such
other method as agreed upon with counsel for the subpoenaing party.
This Request calls for the production of all responsive Documents in Your possession,
custody or control without regard to the physical location of such documents.
. Ifany Document was in your possession or control, but is no longer, state what disposition
was made of said Document, the reason for the disposition, and the date of such disposition.
. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the
original.
. Any copy of a Document that is not identical shall be considered a separate document.
. All Documents shall be produced in the same order as they are kept or maintained by You in
the ordinary course of business.
. Responsive electronically stored information (ESI) shall be produced in its native form; that
is, in the form in which the information was customarily created, used and stored by the
native application employed by the producing party in the ordinary course of business.
DOJ-OGR-00005117
Extracted Information
Document Details
| Filename | DOJ-OGR-00005117.jpg |
| File Size | 888.3 KB |
| OCR Confidence | 94.4% |
| Has Readable Text | Yes |
| Text Length | 2,783 characters |
| Indexed | 2026-02-03 16:56:25.944004 |