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Case 1:20-cr-00330-PAE Document508 _ Filed 11/24/21 Page 22 of 25 and reliability of her accusers’ stories. TR 11/1/2021, pp 27-30. Professor Gershman’s testimony is relevant to that inquiry. How the accusers came to tell the stories that they are now telling is relevant to their credibility. The government has allowed the testimony of the accusers to be corrupted by a group of civil lawyers who have collaborated, for years, in the pursuit of Mr. Epstein. These lawyers have shared information among themselves and their joint clients, developing a “play book” about what should be said to make a claim against Mr. Epstein or the Epstein Victim Compensation Fund. The accusers’ stories have changed dramatically over time and none of these changes has been challenged by the government. Instead, the government either ignores the changes or offers excuses to be adopted by the accusers as the reason for the change. Moreover, avenues of investigation helpful to Ms. Maxwell have been ignored by the government. For example, the government has refused to obtain the accusers’ submissions to the Epstein Victim Compensation Fund and even now is resisting defense efforts to obtain the information. The government refused to obtain I, cxcept for a few pages describing when she first met Epstein months before she claims to have met Ms. Maxwell. When witnesses begin to say favorable things about Ms. Maxwell in interviews with the government the interviews are abruptly terminated. When witnesses do not support the government’s theory they are challenged or cautioned to retain counsel. Professor Gershman, whose credentials and opinions the government does not challenge, has reliable and relevant opinions to offer on these issues, which do not contravene this Court’s rulings on the motions in limine. Finally, there can be no objection to any of Professor Gershman’s opinions if the government “puts the thoroughness of the investigation into issue... .” See TR 11/1/2021, p 29. 18 DOJ-OGR-00008107