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Case 1:20-cr-00330-PAE Document 439 _ Filed 11/12/21 Page 41 of 69 and "good faith” of the New York investigation leading to the charges against her. Kyles, 514 USS. at 445. It is clear from the documents produced by the government that the NPA was the reason why the New York Investigation was opened in late 2018. Ona telephone call with the prosecutors on February 11, 2021, former AUSA gg confirmed that she met with attorneys for some of Epstein’s accusers on February 29, 2016, when she was the Project Safe Childhood Coordinator at the USAO-SDNY, but ultimately did not open an investigation at that time. See Ex. G at SDNY _GM_02742887-91. In late November 2018, however, Julie K. Brown published a series of articles in the Miami Herald entitled “Perversion of Justice,” which were sharply critical of the NPA and the perceived leniency that Epstein received to resolve the Florida Investigation. JJ confirmed that she read the Miami Herald articles when they came out and “‘was very disturbed to read about how the case was resolved in SDFL, which was inconsistent with [her] assumptions when the case was presented by the attorneys in February 2016.” Jd. at SDNY_GM_02742892. [MN further stated that soon afterwards, she spoke to prosecutors in the Public Corruption Unit, including some of the prosecutors on this case, and discussed the Miami Herald articles and her February 29, 2016 meeting with the attorneys. See id. Shortly after that, the New York Investigation was opened. It is also clear from the documents produced by the government, that the government initially focused its investigation on Epstein and did not begin to investigate Ms. Maxwell until after Epstein died on August 10, 2019, roughly one month after he was arrested. To give just one example, the New York FBI did not speak to a single one of the four accusers in this case until after Epstein’s dcath. [jill I 33 DOJ-OGR-00006458