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Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page18 of 52 a — La As Ms. Maxwell detailed in her Motion regarding Rule 404(b) Notice, the government just produced on October 12" " approximately 400 pages of interview reports, notes, documents and other materials related to" |g Mot. at 7. Defense counsel had insufficient time to review, investigate or rebut the admissibility of the materials as direct evidence less than one week later on October 18". For that reason, the Motion did not move to exclude the evidence as direct evidence but rather sought additional time in which to do so. Given the drafting of hundreds of pages of pleadings in the last week, counsel is still unprepared to make the required showing on the direct evidence point and seeks additional time in which to do so. This case has been pending for 15 months, and the government only disclosed gg as a co-conspirator and produced 400 pages of detailed witness statements and notes approximately 10 days ago. Moreover, as discussed in greater detail below, ay ° Bear in mind that the government also moved to exclude evidence that these same "abused" individuals reported to the police that they had no interactions or dealings with Ms. Maxwell. Gov't Motion in Limine at 42 ("The defendant is not charged with committing crimes against [the] victims [who reported that they had no interactions or dealings with Ms. Maxwell].") The fact that the government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony. 12 DOJ-OGR- 00006898