DOJ-OGR-00001132.jpg

Cased 20-€7Q03604AGNt Dibeutre/ptl g70 2File@G2sRM 26acedgs 36 20A5 E. The Discovery Contains No Meaningful Documentary Corroboration of the Government's Allegations Against Ms. Maxwell At the initial bail hearing, the government represented to the Court that “the evidence in this case is strong” and that the allegations of the alleged victims were “backed up |by| contemporaneous documents . . . |including| flight records, diary entries, business records, and other evidence.” (Dkt. 4 at 5.) The Court credited those representations and accepted the government’s proffer that the witness testimony would be “corroborated by significant contemporaneous documentary evidence.” (Tr. 82) (emphasis added). The defense, of course, could not rebut the government’s representations at the hearing because the government had not yet produced discovery. Since then, the government has produced, and the defense has reviewed, hundreds of thousands of pages of discovery, including the entire initial tranche of discovery that the govermnent represented was the core of its case against Ms. Maxwell.’ The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less “significant” corroboration that the Court was led to believe existed. The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994-1997). These documents Daily Mail, “French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending,” (Oct. 25, 2020), https://www.dailymail.co.uk/news/article-88 78 82 5/French-prosecutors-probing-Jeffrey-Epstein-widen-probe- include-Ghislaine-Maxwell html. ° The defense has not yet completed its review of the over 1.2 million documents produced on November 9, 2020 and November 18, 2020. This production includes documents and images seized from electronic devices found at Epstein’s residences in searches of his residences in 2019. Our initial review, however, shows that the documents are from the 2000s and 2010s, well after the charged conspiracy. ww So DOJ-OGR-00001132