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Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 6 of 32 ee. facilitated her sexual abuse, and it was | Epstein himself—not Ms. Maxwell—who purportedly called her to schedule massage appointments, sent her gifts, and encouraged her to recruit other young females to provide massages to Epstein. Indeed, even after interviewing Accuser-4, the USAO-SDFL never found “any specific evidence against” Ms. Maxwell related to the subject of their investigation and thus determined she was not a target of the Florida Investigation.” Epstein, himself, was never charged with federal crimes in connection with the Florida Investigation; ae. Instead, Epstein entered into a Non-Prosecution Agreement (“NPA”) in order to “resolve globally” his own criminal exposure and to immunize and . . 3 any other “potential co-conspirators.” As part of the NPA, Epstein agreed to plead guilty to state prostitution offenses and register as a federal sex offender. He also agreed, in a novel arrangement, to pay for attorneys to represent his victims in civil lawsuits against him and to waive his right to contest damages up to an agreed-upon settlement amount. Accuser-4 took full advantage of the NPA; she received both the benefit of experienced counsel and | resolve her claims against Epstein and his “potential co-conspirators.” Now, over 13 years later, Accuser-4 has surfaced again, except this time with apparently brand-new allegations against Ms. Maxwell. Seemingly unconcerned with the gaping inconsistency in Accuser-4’s prior (and near contemporaneous) recollections, the government has added two new counts charging Ms. Maxwell with sex trafficking offenses under 18 U.S.C. § 1591 (Counts Five and Six) and has dramatically expanded the timeframe of the Mann Act ° Ex. A (Dep’t of Justice, Office of Professional Responsibility, Investigation into the U.S. Attorney’s Office for the Southern District of Florida’s Resolution of its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation, November 2020) (“OPR Report”) at 167 Gnternal quotations omitted). > A copy of the NPA is attached hereto as Exhibit B. DOJ-OGR-00004271