This document is a letter motion from Paul G. Cassell to Judge Sarah Netburn requesting a pre-motion conference to compel Ghislaine Maxwell to produce documents in the case of Jane Doe 43 v. Jeffrey Epstein, et al. The letter outlines disputes over the relevant time period for document production, Maxwell's financial information, employee or business records associated with Jeffrey Epstein, and the adequacy of Maxwell's search for documents. The letter also discusses the need for Maxwell to produce documents related to her communications with Epstein and other defendants, as well as her travel records and financial transactions.
documents/EFTA00805057.pdf
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