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Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 37 of 69 not charge Ms. Maxwell until later in its investigation (the “New York Investigation”). See Mot. at 24. Contrary to the government’s assertion, this evidence is directly relevant to, and probative of, issues of consequence in this case and is therefore admissible on several grounds. Indeed, the government’s motion seems more calculated to preclude evidence that may be embarrassing or reflect badly on the government, rather than evidence that may be inadmissible. A. The NPA Is Admissible to Show the Bias and Interest of Po pS The government has missed a straightforward reason why the NPA is itself admissible: the terms of the NPA apply ‘ [i —and it may therefore be used to show their bias and interest. WE Like any witness subject to a cooperation agreement or immunity agreement, the The NPA also applies to | and can be used to show her financial interest. Under the terms of the NPA, Epstein was required to pay for a lawyer for all the individuals DOJ-OGR-00005492