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Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 11 of 27 In mid-2016 after this second deposition, according to media reports, Giuffre’s lawyers urged the Government to charge Ms. Maxwell with perjury based on her testimony.° It is unclear how the attorneys could have done so without violating the protective order, which forbade them from sharing the contents of these “confidential” depositions with law enforcement. II. The Indictment Count Five of the Indictment alleges that Ms. Maxwell made two false statements during the first deposition in April 2016. Count 5 alleges that the following italicized testimony by Ms. Maxwell was both material and false: Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know. A. I don’t know what you’re talking about. Q. List all the people under the age of 18 that you interacted with at any of Jeffrey’s properties? A. I’m not aware of anybody that I interacted with, other than obviously [the plaintiff] who was 17 at this point. Indictment 21. Count Six alleges that Ms. Maxwell gave false testimony during a subsequent deposition in the same action in July 2016. Count Six alleges that the following italicized testimony from that deposition was both material and false: Q. Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein’s Palm Beach house? A. No, not that Irecall.... Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? 5 Brown, supra n.4. DOJ-OGR-00002420