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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 16 of 26 was never considered a suspect. Ex. B at 10-11, 177, 180-82, 187-96, 241-42, 278. None of Mr. Epstein’s alleged victims said they had seen Ms. Maxwell at Mr. Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her, nor told what to wear or how to act by her. /d. Indeed, none of Mr. Epstein’s alleged victims ever reported to the police they had met or spoken to Ms. Maxwell. /d. Maxwell was not seen coming or going from the house during the law enforcement surveillance of Mr. Epstein’s home. /d. at 214-215. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned before the grand jury. /d. at 203, 211. No property belonging to Ms. Maxwell, including “sex toys” or “child pornography,” was seized from Mr. Epstein’s home during execution of the search warrant. /d. at 257. Detective Recarey, when asked to describe “everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I don’t.” /d. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually trafficking anybody. /d. at 278-79. Detective Recarey was the individual from the Palm Beach Police Department who referred the Epstein case to the FBI in 2006. Detective Recarey entered Mr. Epstein’s home in 2002 to install security cameras to catch a thief and did not observe any “child pornography” within the home, including on Mr. Epstein’s desk in his office. Ex. B at 289-90. III. Lost and Missing Witnesses. The government alleges a three-year time frame for the allegations in the Indictment for acts purportedly occurring on Epstein properties in three states and another country. Had these charges been timely brought, Ms. Maxwell would have interviewed, and subpoenaed as witnesses, the many Epstein employees that were present at the different locations during that three-year period. None of the employees would have corroborated any of the allegations made in the Indictment. 11 DOJ-OGR-00002519