DOJ-OGR-00011368.jpg

Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page6of13 The Honorable Alison J. Nathan December 16, 2021 Page 6 e In February 2020, Jane told the government that Eva was Mr. Epstein’s ex-girlfriend and they stayed friends, just as Mr. Visoski testified. When the group massages began to involve others beyond Mr. Epstein, Ms. Maxwell joined in with Sophie and Eva. Sophie and Eva “knew the routine.” e In August 2021, Jane told the government that Eva was the “Ms Sweden Lady” (Mr. Visoski testified that Eva Dubin was a former Ms. Sweden). At the time, Jane did “not remember” Eva “being involved in massages,” but maybe Eva “aged out of that.” Jd. At the same time, Jane “did not recall there being another Eva.” e Inher testimony in this case, Jane told the jury that Eva was involved in the group sexualized massages with Mr. Epstein, Sophie, and Ms. Maxwell, that she “knew the routine,” and that she “could confirm her story.” The record is clear that Jane has previously claimed (in February 2020) and testified (in this case) that Eva Dubin was involved in the sexualized massages with Mr. Epstein and Ms. Maxwell. Given that allegation, Ms. Maxwell has a constitutional right to call Eva Dubin to the stand and present her testimony, which will deny the allegations and contradict Jane’s claims. Perhaps hoping this Court won’t notice, the government buries most of the facts about Jane’s allegations about Eva in a footnote. Gov. Letter, pp 5-6 n.1. But even that footnote mischaracterizes what Jane said about Eva. Jane did not tell the government that Eva Dubin was not involved in group sexualized massages. At most, Jane said she “does not remember DUBIN being involved in massages.” See 3509-020, p 1. But that’s contrary to what she said in February 2020, and it’s contrary to what she said on the stand. And it’s wholly inconsistent with Jane’s statement that she “does not recall there being another Eva.” /d. at 2. DOJ-OGR-00011368