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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 7 of 26 Tragedies have been forgotten, governments replaced, wars fought. Gen Y has grown up, Gen Z has finished high school and college, Gen Alpha is now in elementary school. In 1994, Facebook, Twitter, Instagram, and Podcasts did not exist. Few people, young or old, communicate today in the same manner, and the record of any communications has largely moved from paper files to smart phone text messages and computer files. The dissemination of information has also changed drastically as social and digital media platforms permit anyone to publish a story, true or false. Once published, the story remains accessible on the internet with just a few search words. The Epstein story is not new. As carly as 1996 but at least by 2006,” the government was aware of allegations that Mr. Epstein solicited females for sex. FBI records reflect that Accuser- 2? was interviewed on November 14, 2006 as part of an ongoing investigation by the government into Epstein and others as documented in FBI case file 31-E-MM-108062-49. The 2006 interview contained some of the allegations made in the Indictment. Investigative referrals appear to have been made to various FBI offices located in the same cities as those alleged in the Indictment. It was no secret that Ms. Maxwell was Mr. Epstein’s employee and friend in the 1995-to- 2000 timeframe. It also was no secret that Epstein worked out a deal with the government that * According to the New York Times, in 1996 Maria Farmer “contacted the New York Police Department, and said she then went to the Federal Bureau of Investigation, offering to share what she knew about Mr. Epstein and the parade of young women being brought to Mr. Epstein’s houses.” See, https://www.nytimes.com/2019/08/26/us/epstein-farmer-sisters-maxwell.html. Of course, no FBI 302 has been produced corroborating this account. > Although the Indictment refers to them as “Minor Victims” One through Three, there has been no finding by any court or jury that these now-adult women are in fact “victims.” Use of those terms thus violates Ms. Maxwell’s presumption of innocence, and counsel will refer to them throughout as “Accusers” One through Three or “Accusers.” See, e.g., Oregon v. Sperou, 442 P.3d 581 (Or. 2019) (use of word “victim” by prosecutors and state witnesses during trial violated presumption of innocence and constituted improper witness vouching). DOJ-OGR-00002510