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Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 18 of 34 Two of the sources in the Daily News article insisted there was a second meeting in the summer of 2016.1 In addition, as described above, AUSA [in 2021 said she recalls contemplating a perjury prosecution of Maxwell. Ex. K, p 5. But if there were only the one meeting, it makes little sense for AUSA J to have been thinking about a potential perjury prosecution in February of 2016, before Maxwell had even been deposed (unless the plan was to set a perjury trap for Maxwell). It is more likely that AUSA J contemplated a perjury prosecution after a second meeting with Giuffre’s attorneys, which took place after at least one of Maxwell’s depositions. As reported in the Daily News, “David [Boies] was particularly frustrated by the failure to pursue a perjury charge.”!? “We have her dead to rights,” he said.“ This Court cannot accept without further inquiry the government’s assertion that there wasn’t a second meeting or any further contact between the U.S. Attorney’s Office and Giuffre’s attorneys. At a minimum, an evidentiary hearing is required. e Defense 5: AUSA gg had no idea what was in Boies Schiller’s files. The government stands by the claim that AUSA J had “either little or no additional information than [Judge McMahon did] in terms of what materials there are [and] who was deposed” and, for all the government knew, the deposition transcripts would show “page after page of people taking the Fifth.” See Resp. at 70. The government’s Response is not credible. 2 Supra Note 10. 3 Supra Note 10. 4 Supra Note 10. 13 DOJ-OGR-00004153