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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 14 of 26 bank records, records of payments to alleged accusers, facsimile transmissions, emails, and phone records. Presumably the government will argue that any reliance on Epstein testifying is speculative because he may have asserted a Fifth Amendment privilege against self- incrimination. See United States v. Capone, 683 F.2d 582, 589 (1st Cir. 1982). Not so. Epstein was indicted in 2019. Any privilege against self-incrimination would have been lost as a result of his acquittal or final conviction prior to any trial in this matter. B. Paula Epstein. Paula Epstein was Jeffrey Epstein’s mother. She died in April 2004. Had this prosecution been brought in a timely manner, Ms. Epstein would have testified that Ms. Maxwell spent considerable time with her while in the Palm Beach, Florida area. Ms. Epstein would have testified that she did not observe Ms. Maxwell with any Accusers between 1994 and 1997. Ms. Epstein would have provided accurate information about Ms. Maxwell’s relationship with Mr. Epstein, dates and times that she was with Ms. Maxwell, and presented a compelling counter to the specious allegations that Ms. Maxwell traveled for purposes of grooming accusers for Mr. Epstein. Ms. Epstein would have been able to portray Ms. Maxwell as a caring and compassionate human being and would have discussed the many days that the two were together. She would have testified that Ms. Maxwell was her caregiver when she was sick and injured. C. Michael Casey. Mr. Casey died on August 9, 2017. Mr. Casey was the agent of the person believed to be, but not identified by the government, Accuser-1. Mr. Casey had knowledge about Accuser-1’s interactions with Jeffrey Epstein and the lack of any interaction with Ms. Maxwell. Mr. Casey, were he available to testify, would establish the whereabouts of Accuser-1 during the relevant time periods and Ms. Maxwell’s absence from those locations. Mr. Casey, while working with Accuser-1, did not relate any complaints about Ms. Maxwell to any authority, Ms. Maxwell, or DOJ-OGR-00002517