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Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 24 of 26 interest to stop what would have been a one-way discovery process in favor of Ms. Maxwell, the government moved to intervene, representing to Magistrate Judge Freeman, among other things, that: e “should discovery in civil action go forward, multiple witnesses or potential witnesses at the criminal trial would be subject to deposition” e “any concern regarding the potential delay of this civil suit is outweighed by the concer that Maxwell would seek to assert her Fifth Amendment rights rather than submit to a deposition in the civil action, and that depositions of other witnesses could potentially interfere with the criminal prosecution” e “permitting any discovery to proceed in this lawsuit would enable Maxwell to seek a preview of trial testimony in the criminal case, and would afford her with a broader array of discovery than she is entitled to in the criminal case” e “a complaint concerning sexual abuse of minors by Epstein and Maxwell will inevitably implicate documents, witnesses, and other evidence that overlaps with the criminal matter, whether or not the plaintiff in this action—or the conduct she alleges—has any direct connection to the charges in the Indictment” Case No. 20-cv-484, Dkt. 80. These admissions make clear that the government was aware of the substantial overlap between the allegations it investigated more than a decade before this Indictment. The sharp contrast between the government’s actions in this Jane Doe civil matter, and the Annie Farmer civil matter, the Giuffre matter, and the Ransome matter also establish a strong inference that as long as the government stood to gain a tactical advantage by delaying the indictment (the sought- after deposition in the Farmer civil litigation), it would not move to intervene. However, where the government’s tactical advantage was lost or threatened (Jane Doe) it would shut the case down. CONCLUSION Ms. Maxwell requests that the Court dismiss the Indictment because of the prejudicial and tactical delay by the government in prosecuting this case. 19 DOJ-OGR-00002527