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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page9of25 The Honorable Alison J. Nathan November 22, 2021 Page 9 Maxwell and the jury have a right to know to what extent, if any, the accusers claimed that Ms. Maxwell was involved in the alleged abuse. As this Court well knows, the accusers have been anything but consistent on this front. Accuser-4, for example, was first interviewed by the FBI about Epstein in 2007. At that time, she told the agents that she was recruited to provide massages to Mr. Epstein by Virginia Giuffre, f/k/a Roberts, not Ms. Maxwell. She did not describe any grooming by Ms. Maxwell or even any participation by Ms. Maxwell in any crime. In this interview, Accuser-4 describes Ms. Giuffre as the person who showed her what to do with Epstein and relates that Ms. Giuffre had sex with Mr. Epstein while Accuser-4 watched. Sarah Kellen was her contact person and the person who took naked photos of Accuser-4 in exchange for $500. Ms. Maxwell’s name does not appear in the FBI 302. Shortly after this interview Accuser-4 sued Epstein and Kellen, not Maxwell. The first complaint, filed in Florida state court does not mention Ms. Maxwell. The complaint was amended and removed to U.S. District Court and in over 200 paragraphs Ms. Maxwell’s name appears not once. In her answers to written discovery and in deposition testimony Accuser-4 does not accuse Ms. Maxwell of any misconduct, but instead affirms that she has told the entire story which, according to Accuser-4 (then), began in 2002 and ended in 2003. These claims were settled by Accuser-4 for a substantial amount of money and a release was executed for all claims against Epstein, Kellen, and related individuals or entities. It was not until after Epstein died and one month after the EVCF was created that the lawyers for Accuser-4 contacted the government to say that Accuser-4 wanted to meet. The lawyers were helpful enough to provide to the government a new list of “persons” and “topics” for the government’s DOJ-OGR-00011432