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Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page17 of 34 The government’s claim also fails on its own terms. The article is not meaningfully anonymous.!” Among others, the article quotes David Boies, who said: We were saying to anyone who would listen: We’ve got clients who were abused. Some of them were underage. We have the evidence. There’s a whole record that’s been developed. We can establish beyond any reasonable doubt there was a massive sex trafficking ring going on. The article also quotes Brad Edwards, who describes in his self-published memoir the various contacts Giuffre’s attorneys had with the U.S. Attorney’s Office in 2016. Finally, as detailed above, AUSA [g}contemporancous notes confirm most of the article’s substance.'! Ex. J. e Defense 4: There was only one meeting. The government denies there was a second meeting between the U.S. Attorney’s Office and Giuffre’s attorneys. Resp. at 92. This denial, though, is based solely on AUSA foggy memory and in the absence of any credible investigation. Contrary to the government’s claim, the evidence strongly suggests there was a second meeting or some further contact between them. At the very least, this Court should hold an evidentiary hearing to find the truth. '© Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https:/Awww.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzhl7zdrzdgrbbs7yc6bfnszu-story. html. To the extent the article relies on unnamed sources, there is no indication those sources are anonymous in the sense that the author is unaware of their identity. In the 2021 call, the government apparently did not ask AUSA [ggg whether she was one of the unnamed sources. See Ex. K. '! The government also says the article is hearsay. Resp. at 89. This is an odd claim for the government to make while asking this Court to credit double hearsay: someone’s notes of statements made by AUSA J during a phone call. The government’s hearsay argument does nothing but support Maxwell’s request for an evidentiary hearing. 12 DOJ-OGR-00004152