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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 32 of 37 topless massage. Tr. 2075. However, because of the passage of time, the available Shoppers Travel records only went back as far as 1999. Tr. 2393. Asa result, the defense did not have access to Shoppers Travel records to challenge Annie Farmer’s recollection of when the trip to New Mexico occurred. Likewise, Jane testified that she traveled with Epstein approximately ten times when she was under the age of 17 on both his private jet and on commercial flights, and that she was first sexually abused in New York when she was 14. Tr. 316. As discussed, the flight logs showed only two such trips on Epstein’s plane. The Shoppers Travel records would have shed light on the number of commercial flights that Jane took when she was a minor and could have been used to challenge her recollection of events, including whether she even traveled to New York before she was 16 years old. B. Financial Documents — Bank Records and Credit Card Records Critical financial documents were also unavailable to the defense. In its summation, the government gave particular emphasis to bank records which seemed to show that Epstein transferred approximately $30 million to Ms. Maxwell from 1999-2007, arguing that it was Ms. Maxwell’s payment for facilitating his sexual abuse of young girls for over a decade. Tr. 2841, 2884-85. Because the transactions were between 15-20 years old, there were no bank records apart from Epstein’s Bears Sterns statements that the Palm Beach FBI had obtained in 2006-2007 to explain what the transfers were for. The defense was unable to obtain any records related to the accounts into which the money was transferred. The defense therefore could not challenge the government’s claims about the purpose of the funds or that Ms. Maxwell even controlled the accounts. Furthermore, there were no credit card records available for Epstein going back to the 1990s. Accordingly, the defense could not use these records to test critical dates, like when Epstein bought the pair of cowboy boots for Annie Farmer or the movie tickets to Primal Fear, 2/ DOJ-OGR-00008956