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Case 22-1426, Document 59, 02/28/2023, 3475902, Page26 of 113 INTRODUCTION The Government prosecuted Ms. Maxwell (“Maxwell”) as a proxy for Jeffrey Epstein (“Epstein”). It did so to satisfy public outrage over an unpopular non-prosecution agreement and the death of the person responsible for the crimes. In its zeal to pin the blame for its own incompetence and for Epstein’s crimes on Maxwell, the Government breached its promise not to prosecute Maxwell, charged her with time-barred offenses, resurrected and recast decades-old allegations for conduct previously ascribed to Epstein and other named assistants, and joined forces with complainants’ civil attorneys, whose interests were financial, to develop new allegations that would support charges against Maxwell. Immediately after Epstein’s death, complainants’ civil attorneys representing Epstein victims, including those who testified at trial, began to assist in the creation of the Epstein Victims Compensation Program (VCP), a non-adversarial and confidential claims resolution program set up to compensate self-identified victims of Epstein, even as they were actively involved in the Government’s investigation. On June 25, 2020, the Program began accepting claims. An attorney for one complainant encouraged her to cooperate with the Government in its case against Maxwell because it would improve her prospects for receiving a larger sum of money from the VCP. Tr. 2731-32. It did. “Jane” received $5,000,000. DOJ-OGR-00021073