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Case 1:20-cr-00330-PAE Document 705 - Filed 07/12/22 Page2of12 The Honorable Alison J. Nathan May 12, 2021 Page 2 produce Brady material with various disclaimers such as “although the government is not obligated to do so” (Dkt. 269 pp. 8, 9), and obfuscate the importance of legitimate defense requests for discovery. The government repeatedly demonstrates that it views this process not as a search for the truth, but for a conviction at any cost, including the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Seven (7) photocopied pages of this journal, two of which are the front and back covers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Accuser-2 relied on select portions of the journal in public discussions with various representatives of the media and claims to have looked at the journal to “refresh [her] memory about this time.” See, e.g., Michael Baker, "The First Women to Report Jeffrey Epstein,” The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying to refresh my memory about this time, I came across this journal entry. [Host] [Accuser-2] has this journal from that time period. It's a spiral journal with a picture of two sisters on the front.").! When it suits its purpose, such as arguing against bail, the government touts the journal as powerful evidence, to wit, “Contemporaneous journal entries corroborate details of another ' Podcast audio and transcript located at https://www.nytimes.com/2019/08/26/podcasts/the- daily/epstein-maxwell-farmer-sisters.html?showTranscript=1. DOJ-OGR-00011242