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Case 1:20-cr-00330-AJN Document 52 Filed 09/02/20 Page 4 of 8 The Honorable Alison J. Nathan August 17, 2020 Page 4 any Subpocr. In or about February 28, 2019 the government first applied to gg for relicf. Jy During these ex parte proceedings, the government made numerous unchallenged factual assertions. To Ms. Maxwell’s knowledge, no one disclosed the pendency of these applications {c [Ill Certainly, no one -- not the government, any court, or J -- disclosed to Ms. Max Wl government arrested Ms. Maxwell. On July 8, the government filed a superseding indictment alleging that Ms. Maxwell “assisted, facilitated, and contributed” to Epstein’s abuse of minors. the indictment alleges that in 2016 Ms. Maxwell made “efforts to conceal her conduct” by “repeatedly provid[ing] false and perjurious statements” in deposition testimony. Superseding Indictment, Doc. # 17 at 29 8. aS GS EERE. On the two applications referenced abovc Il Ree tc two SDNY courts rendered a split decision. yyy a 22nicd the cx ° The first batch of discovery was provided by the government to NY counsel on August 5, 2020 in the late afternoon on a hard disk. Due to the time upload and securely transfer files, undersigned counsel for Ms. Maxwell (also counsel for her in the Giuffre case) only received these materials at 11:38 a.m. on Friday, August 7, 2020. DOJ-OGR-00001755