DOJ-OGR-00008243.jpg

Case 1:20-cr-00330-PAE Document528 Filed 12/06/21 Page7of8 Government would have aided Jane’s claim before the Epstein Victims’ Compensation Fund and that Jane was aware of that fact, as the defense has already argued. And insofar as the point is to impeach Jane, this statement is of minimal impeachment value. Jane said no when asked whether she knew that “cooperation with the government, including testifying, would benefit you in your civil litigation against the Epstein estate and Ms. Maxwell.” 12/01/21 Tr. at 581; see id. (asking the same question about her knowledge “at any point” regarding Jane’s civil litigation). As of August 17, 2021, the date of the statement from Glassman to the Government, Jane had been paid by the Epstein Victims Compensation Fund, and her civil case had been dismissed. And Glassman appears to have advised Jane that the civil cases were fully resolved. See 12/01/21 Tr. at 619 (testimony by Jane that she does not have a financial stake in the outcome of this trial).4 At most, then, the statement means that Glassman, at some point in the past, advised Jane that testifying would aid another “case.” And at most, that would impeach Jane by suggesting that, while she accurately testified that she did not “know” that her “cooperation with the government, including testifying,” would benefit her in her civil case or EVCP claim, she had been told that at one point in the past. By contrast, there is significant risk that admission of the statement would require Glassman to divulge further privileged communications with Jane. Glassman’s comment to the Government is not easily intelligible. Glassman referenced “help[ing] her case,” which is not specifically a reference to civil litigation or her claim with the EVCP, and says that “it,” whatever it is, would help that case. (Def. Letter Ex. A). To explain what Glassman is referencing, and when he gave that advice, he would likely have to provide more content to his advice to Jane and * The Government is of course not aware of Glassman’s privileged advice to Jane. 7 DOJ-OGR-00008243