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Case 1:20-cr-00330-PAE Document 293 _ Filed 05/25/21 Page 28 of 32 (5) The dates when, and locations where, Ms. Maxwell allegedly paid Accuser-4 “hundreds of dollars in cash.” Ud. 99 9d, 25a). (6) The dates when, and locations where, Ms. Maxwell allegedly “encouraged [Accuser-4] to recruit other young females to provide sexualized massages to Epstein.” (Ud. JJ 9d, 25b). (7) The dates when, and locations where, Ms. Maxwell allegedly “invited [Accuser-4] to travel with Epstein” and “offered to assist [Accuser-4] with obtaining a passport for purposes of such travel.” (Ud. § 9d). (8) The dates when, and locations where, Ms. Maxwell allegedly “sent [Accuser-4] gifts.” Ud. 9¥ 9d, 25c). (9) The dates when, and locations where, Ms. Maxwell allegedly called Accuser-4 “to schedule appointment for [Accuser-4] to massage Epstein.” (Id. J 9d, 25d). (10) The dates when the conspiracy charged in Count Five began and ended. (Id. 23). (11) The identities of the “others” who allegedly participated in the conspiracy charged in Count Five with Epstein and Ms. Maxwell. Ud. 9] 23-24). (12) The identities of any individuals who were enticed to travel, or were transported, in interstate or foreign commerce to engage in illegal sexual activity with Epstein during the time period of the charged Mann Act conspiracies (1994-2004), apart from Minor Victims-1-4. (Ud. JJ 13, 19). VII. The Court Should Order the Government to Produce Accuser-4’s Prior Statements as Brady Material. As explained above, it is apparent from the non-testifying witness material, which the government produced just a few weeks ago on April 13, 2021, that Accuser-4 has only recently included Ms. Maxwell in her allegations of sexual abuse. In her summary of Accuser-4’s allegations that she gave to the SDFL grand jury on March 18, 2008, Special Agen i made no mention of Ms. Maxwell, indicating that Accuser-4 never discussed Ms. Maxwell when the FBI interviewed her in connection with the Florida Investigation. Indeed, it is clear from the grand jury testimony that Accuser-4 implicated ae. not Ms. Maxwell. Only now, 13 years after she first reported these events to the Palm Beach FBI and several months after Ms. 24 DOJ-OGR-00004293