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Case 1:20-cr-00330-PAE Document 293 _ Filed 05/25/21 Page 11 of 32 Epstein from 2001 to 2007”)). Thus, the time period alleged in both Counts Five and Six falls squarely within the date range covered by the NPA for which Ms. Maxwell is immunized. Moreover, 18 U.S.C. § 1591(a) is one of the five enumerated offenses in the NPA. (Ex. B at 2 of 7). As such, Counts Five and Six are clearly offenses covered by the NPA. Ms. Maxwell also cannot be prosecuted on Counts Five and Six because they are based on the exact same allegations that were already thoroughly investigated by the Palm Beach FBI and USAO-SDFL and were presented to a grand jury in the Southern District of Florida in connection with the Florida Investigation. The allegations underlying Counts Five and Six (and the expanded date range for Counts One and Three) come from a single accuser—Accuser-4— who alleges that Epstein sexually abused her from approximately 2001-2004 and that Ms. Maxwell allegedly facilitated that abuse. (S2 Indictment 99 9d, 22-27). Based on our review of the prior statements of non-testifying witnesses, which the government only recently produced to the defense on April 13, 2021, we know that FBI Special Ac | i i interviewed the person we believe to be Accuser-4 in connection with the Florida Investigation. (Ex. C at 22:1-17).* We also know that Special Agen i presented her allegations— the very same allegations that form the basis for Counts Five and Six—to the grand jury in the Southern District of Florida in support of a proposed 60-count federal indictment of Jeffrey Epstein a. (id. at 22:17-31:6). The indictment included a conspiracy count and a substantive count alleging a sex trafficking offense involving Accuser-4. (/d. at 28:3-15 (Accuser-4’s allegations formed the basis for “Overt Acts One through 18” and Count Two of the proposed indictment charging Epstein LF with “procur[ing] [Accuser-4] to “ Exhibit C is a transcript of the March 18, 2008 grand jury testimony of Special Accn the lead case agent in charge of the Florida Investigation, in which she summarizes her interview of Accuser-4 and other related evidence. DOJ-OGR-00004276