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Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 14 of 16 Again, the government states that the report inculpates Ms. Maxwell. (Opp. 186-87). But even the unredacted portions of the report reveal material inconsistencies Lr es cite just one example, I (ee Exivic A at 85). We believe the unredacted version of the report will reveal numerous additional inconsistencies and demonstrably false statements that directly undermine fF credibility and the veracity of her allegations against Ms. Maxwell. Accordingly, the unredacted report should be disclosed.’ Third, Ms. Maxwell must have access to and be able to inspect the original, complete copy of the diary, rather than i i (;wtstisdzd that were produced in discovery. The government has repeatedly referenced the diary, es as one of the most significant pieces of corroborating evidence in its case. Yet the government has blindly accepted the author’s assurances that fs ee Lo And as expected, the government disavows any responsibility for producing it to the ° Although the name of the person who spoke to Ms. Giuffre’s father is redacted in the report, Ms. Giuffre alleged in her 2009 civil complaint against Epstein that Ms. Maxwell spoke to her father. See Jane Doe 102 v. Jeffrey Epstein, 09-cv-80656-KAM (SDFL 2009), Dkt. 1 717. ™Ms. Maxwell confirms that the government produced an unredacted version of the other FBI report she requested at Bates range SDNY_GM_00380550 through SDNY_GM_000380554. (Opp. 186). 11 DOJ-OGR-00004241