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Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page3of12 The Honorable Alison J. Nathan May 12, 2021 Page 3 victim’s account, including the details of when, where, and how that victim came to meet Epstein.” Dkt. 100 p. 11. And, the government has signaled its intent to introduce these pages at trial, arguing that there is no “basis for doubting the authenticity of the documents which the Government expects that [Accuser-2] will be able to properly authenticate at trial.” Dkt. 268, p. 5. What did, or did not, happen “about this time” and what Accuser-2 recorded, and did not record “about this time” is relevant, exculpatory, evidence. The government admits it does not have the remaining pages of the journal and admits that it has made no effort to read the remaining pages of the journal. This does not stop the government, however, from expressing baseless opinions about the journal’s content, relevance, or admissibility because, in the blind search for a conviction regardless of the truth, ignorance is indeed bliss. The government implies that the journal, here, has “been evaluated for Brady material” (Dkt. 269 p. 4) which is not true. Free from any actual knowledge, the government liberally makes unfounded and misleading claims like: e “The remainder of the diary consists of [Accuser-2’s] unrelated personal diary entries;” Ud., p.3) e “(T]he diary contains no relevant material;” (/d., p. 4) e The diary is “full of [Accuser-2’s] personal and unrelated information;” (/d., p. 4 n.1) e The diary is “likely to sweep in a significant period of [Accuser-2’s] life before [she] met Epstein....” (/d., p. 6) The government makes additional questionable, contradictory, statements regarding the journal. The government offers that it “understands” that the item requested is Accuser-2’s “entire diary from her teenage years.” (/d., p.2) The “understanding” has no factual attribution DOJ-OGR-00011243