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Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 8 of 34 o That Maxwell and Epstein-friend gg “took sexually explicit photos of [Giuffre] regularly.”? Jd. o That, as a birthday present, Maxwell gave Epstein a sexually explicit photo of Giuffre taken when Giuffre was sixteen.’ /d. o That Epstein hung the photo on one of his walls.* /d. o That Giuffre has a note in Maxwell’s handwriting with the name of another victim. Id. at 8.° o That Giuffre was “live in” sex slave from 2000-2002.° Jd. at 3. o That there were other victims of Epstein and Maxwell, including yyy ME. i. at 7, who is apparently Accuser-1 in this case, and another woman whose description matches ME. i@. at 9, who is apparently Accuser-3. o That Accuser-1 was “highly credible.” /d. at 7. o That Epstein and Maxwell used “the same MO with” Accuser-3 that they used with Giuffre. /d. at 7, 9. o And that Giuffre “wants [a] prosecution.” /d. at 7. ? Maxwell denies ever taking any photos of Giuffre, and we have seen no sexually explicit photo of Giuffre in any of the civil or criminal document productions. 3 Not only did Maxwell not meet Giuffre until Giuffre was seventeen years old, Maxwell never provided any such photo to Epstein, nor, to our knowledge, has any such photo ever been produced, in the civil or criminal cases. 4 Again, we have not seen any such photo produced in any discovery, either in the civil or criminal cases. ° We are aware of no note in Maxwell’s handwriting being produced in the Giuffre action, or the criminal discovery. ® Giuffre was in fact living with her fiancé at the time and held multiple other jobs, as later confirmed through depositions and documents in the Giuffre action. DOJ-OGR-00004143