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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 76 of 93 Formal / Informal Immunity of Government Witnesses [If applicable] You have heard the {testimony of an accomplice witness. — £4i&S who was a co-conspirator of Jeffrey Epstein. but who was not charged as a defendant in this case. | under a grant of immunity from this Court. What this means is that the testimony of the witness may not be used against him or her in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with the immunity order of this court. Because of the interest an accomplice may have in testifying should be scrutinized with great care and viewed with particular caution when you decide how much of that testimony to believeSvehtestimenyshould be semtinized by ou ith createare and-yeu- should act uper itivith eautiern. You should consider whee Ts: a motive to testify falsely. You should examine her testimony + closely to determine whether or not it is es Commented [CE93L submits that these edits | colored in such a way as to place guilt upon +he- defendants. Maxwell in order to further he fc omax asomnsaneal ees Commented [RA(94R93]: GOVERNMENT RESPONSE: avitnessesther own interests. If you believe the testimony to be true and determine to accept it, (1)The defense’s proposed changes include language typically used when the witness is testifying pursuant to an you may give it such weight, if any, as you believe it deserves. agreement with the Government Employee-1 has no such agreement and is merely testifying under a grant of immunity Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. (2)The defense will likely argue that Employee-1 is not a 7-8; and the charge of the Hon. Loran G. Schofield in United ee ae herent should not States v. Calk, 19 Cr. 366 (LGS). ener wears cin salatry hese nie particular caution because she was a co-conspitator 76 DOJ-OGR-00006142