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Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 15 of 23 Contrary to the government’s misrepresentations, J did foment the investigation (or at least it tried to). And the evidence of “collusion” between the government and (i was ample, tracing to at least early 2016 and precisely designed to have Maxwell charged with perjury.° i I) [i OO —SC“‘C;iés es —S—SSCSC —CCCSCités. E. EE Separately Rejects An Identical Gambit By The Government Around the same time that J cranted the government’s ex parte request, ee ©)ccted an identical request from the government in a different civil government’s conduct for what it was: an attempt to deprive Maxwell of notice and an opportunity to be heard. Ex. H. Indeed, J rebuffed the government even after it alerted her (0 TS order. Ex... As i! found, a a 6, aS 2: BE was all too eager for the government to investigate and prosecute Maxwell: ° Maxwell has not yet been provided discovery of whether | shared actual sealed materials or the contents of sealed materials during its meetings with the United States Attorney’s Office in 2016. As noted below, the bare minimum that is required here is an evidentiary hearing to probe the extent to which J “colluded,” in a Chemical Bank sense, with the prosecutor’s office. 10 DOJ-OGR- 00002362