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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 18 of 26 e Day-Timer records from 1994-1997; e Tax records from 1994-1997; e = Travel records from 1994-1997; e Business records from 1994-1997; e Credit card or ATM records — including, e.g., records of shopping trips, trips to the movies and; e Checking account records. 2. Mr. Epstein’s e Phone records from 1994-1997; e Emails from 1994-1997; e Day-Timer records from 1994-1997; e Tax records from 1994-1997; e = Travel records from 1994-1997; e Business records from 1994-1997; e Mr. Epstein internal email “Citrix” communications; and e Business Records in the Palm Beach, Santa Fe, or New York area reflecting purchases of goods or services. The documentary evidence would establish that Ms. Maxwell did not travel as alleged in the Indictment; did not conspire with Mr. Epstein, as alleged in the Indictment, and was not present with either Mr. Epstein or any Accuser for significant periods of time between 1994 and 1997. Business records associated with the property identified in the Indictment would detail various employees who worked at the properties during the relevant times. These individuals, were they to be located, would corroborate that they did not observe Ms. Maxwell behaving in any of the behavior alleged in the Indictment. The government has withheld any meaningful discovery relating to when or where any overt acts allegedly occurred. If Ms. Maxwell had this 13 DOJ-OGR-00002521