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Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page17 of 25 The Honorable Alison J. Nathan November 22, 2021 Page 17 redacted), so she is already aware of the content of the EVCP’s general release.”” EVCP Mot. at 11-12. As is implicit in this argument, however, Ms. Maxwell does not have all or even complete releases from each accuser. Ms. Maxwell has a redacted release from Accuser-2 and a release from Accuser-1.° But she does not have releases from either Witness-3 or Accuser-4. Nor does Ms. Maxwell know if those releases are identical to Accuser-1’s redacted release or Accuser-2’s release. Conspicuously, the EVCP makes no representation that the content of the releases is identical. EVCP Mot. at 12. Ms. Maxwell thus cannot assess what her accusers gave up in exchange for millions of dollars and whether they might even have released claims against Ms. Maxwell herself. Nor can she use the releases she does not have (and the one she does) as trial exhibits in this case. 3. Materials Submitted to the EVCP. No one disputes that the submitted materials are not otherwise procurable. This Nixon factor is satisfied. 4. Communications. No one disputes that the communications are not otherwise procurable. This Nixon factor is satisfied. > For the release from Accuser-1, it was produced under restriction, and to use it during this , a DOJ-OGR-00011440