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Case 1:20-cr-00330-AJN Document 182 Filed 04/15/21 Page 3 of 8
LAW OFFICES OF BOBBI C. STERNHEIM

materials in the MDC. Although defense counsel have not yet been able to fully review the
materials, which are voluminous, it is apparent that the witness interviews contain exculpatory or
otherwise favorable information for Ms. Maxwell, which the defense has an obligation to
investigate. A number of these witnesses may testify as part of the defense case. Even if defense
counsel were to attempt to contact and interview only a small number of these witnesses and
conduct any necessary follow-up investigation, that would still take a significant amount of time
to complete. Thus, while we appreciate receiving these materials, the disclosure has not
decreased the amount of time the defense will need to investigate; indeed, it has increased it.

It is also disingenuous for the government to argue that because it previously provided
discovery regarding the new charges no additional time is required to prepare the defense of the
new indictment. When the parties were originally negotiating a discovery schedule for the
original indictment, the government represented that it would be providing, in an abundance of
caution, a significant amount of discovery from Epstein’s seized electronic devices that
contained information that it was not relying on in Ms. Maxwell’s case. The government
reiterated this point in its November 6, 2020 letter to the Court requesting additional time to
finish producing discovery. (See Dkt. 69 at 4 (“[O]f the approximately 1.2 million documents,
only a handful were specifically relied upon by the Government in the investigation that led the
charges in the current indictment.”). These devices contain over 2.4 million pages of material,
virtually none of which pertained to the time period of the original indictment. Now that the
superseding indictment has expanded the time period of the alleged conduct well into the 2000s,
the 2.4 million pages that were not previously relevant are now pertinent, requiring re-review and
analysis.¹

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¹ The actual number of pages is, in fact, larger than 2.4 million. For example, the discovery from these devices
included forensic Cellebrite images of several individual devices that were assigned a single Bates number.

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