DOJ-OGR-00002526.jpg

Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 23 of 26 Maxwell. Indeed, BSF attorneys had met with the Southern District of New York’s USAO at least once (and likely twice) in 2016, urging that office to prosecute Ms. Maxwell. [i ES ¢011¢c1¢1 in the Giuffre civil litigation. Discovery in this case has not revealed when Ms. Farmer met with the prosecutors, but it is fair to assume that as of April 2020, she had done so. The Motion to Stay was heard on May 22, 2020 by Magistrate Judge Debra Freeman. /d., Dkt. 80. During that phone conference, Judge Freeman ruled that a temporary stay was justified as to discovery from Ms. Maxwell due to the ongoing criminal investigation. /d. She ruled that no deposition nor interrogatories could be sought from her for the foreseeable future, but that other discovery could proceed. /d. A short time later, on June 19, BSF reversed its position. Recognizing it could not provide further discovery to the government from Ms. Maxwell through a deposition in the Farmer case, BSF then said it did wish to have the case stayed in its entirety while plaintiff participated in the Epstein payment program. /d., Dkt. 84. The Court granted that motion on June 22, 2020. /d., Dkt. 85. The Sealed Indictment in this matter was returned one week later, on June 29 and unsealed on July 2. /d., Dkt. 1. The government has not provided Ms. Maxwell with discovery regarding its communications with BSF. The timing of the partial stay and the reversal of the previous aggressive posture by BSF cannot be mere coincidence. D. Jane Doe v. Indyke, Case No. 20-cv-00484 (JGK). This action was brought against the Estate of Mr. Epstein and Ms. Maxwell by civil complaint, filed in this district on January 22, 2020. Ms. Maxwell surmises, but does not know, that the Jane Doe in this matter is so called Accuser-1. When it became clear that Ms. Maxwell (having been indicted) would exercise her Fifth Amendment Privilege against self-incrimination and it was therefore in the government’s tactical 18 DOJ-OGR-00002526