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Case 1:20-cr-00330-PAE Document544 Filed 12/14/21 Page2of9 The Honorable Alison J. Nathan December 13, 2021 Page 2 attorneys themselves and agents of the government, and all are relevant to show how and why Ms. Maxwell’s accusers came to cooperate with the prosecution and testify against Ms. Maxwell. The questions are relevant to motive and bias, and because the answers are not privileged, this Court should permit Ms. Maxwell to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as witnesses. Despite this Court’s invitation, the government refused to stipulate to the testimony Ms. Maxwell seeks from Mr. Glassman. In an effort to avoid a dispute, Ms. Maxwell also inquired whether the government would be willing to stipulate as to Mr. Scarola’s and Mr. Edwards’ testimony. Without disputing Ms. Maxwell’s contention that their testimony is not shielded by the attorney-client privilege, the government nonetheless again refused to stipulate. A, Jack Scarola Ms. Maxwell anticipates that Mr. Scarola would be questioned on the following non- privileged topics, which primarily relate to his acting as a conduit between Carolyn and the government. All the information Ms. Maxwell seeks to elicit taken from government 3500 disclosures about Carolyn. The essence of the testimony is the following: e Mr. Scarola is an attorney licensed to practice law in the state of Florida. e Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah Kellen in 2008 and 2009. e Mr. Scarola sent an email to Assistant United States Attorney Rossmiller in August 2019, copying other attorneys who represented alleged victims of Jeffrey Epstein, including Robert C. Josefsberg and Mr. Edwards. DOJ-OGR-00008365