Giuffre_Maxwell_Batch5_p00004.png

Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 3 of 13 Dershowitz, Prince Andrew, and others. Further efforts from the Government to avoid producing any discovery followed (see generally DE 225-1 at 4-5), ultimately leading to a further Court ruling in June 2013 that the Government should produce documents. DE 189. The Government then produced about 1,500 pages of largely irrelevant materials to the victims (DE 225-1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons, attaching an abbreviated privilege log. 8. While these discovery issues were pending, in the summer of 2014, Mr. Edwards and I contacted Government counsel to request their agreement to add two additional victims to the case, including Ms. Virginia Giuffre (who was identified in court pleadings as “Jane Doe No. 3”). Edwards and I sought to have her added to the case via stipulation, which would have avoided the need to include any detailed facts about her abuse. Weeks went by and the Government ~— as it had done on a similar request for a stipulation to add another victim — did not respond to counsel’s request for a stipulation. 9. Finally, on December 10, 2014, despite having had four months to provide a position, the Government responded by email to counsel that it was seeking more time, indicating that the Government understood that victims’ counsel might need to file a motion with the court on the matter immediately. DE 291 at 3-5. Rather than file a motion immediately, victims’ counsel waited and continued to press the Government for a stipulation. See id. at 5. Finally, on December 23, 2014 — more than four months after the initial request for a stipulated joinder into the case — the Government tersely indicated its objection, without indicating any * Jeffrey Epstein also attempted to block discovery of materials, leading to an Eleventh Circuit tuling that the victims’ discovery efforts were proper. Doe v. Epstein, 749 F.3d 999 (11th Cir. 2014).