EFTA00078067.pdf

From: (USANYS)" To: at aa Subject: RE: Draft Maxwell Indictment Date: Thu, II Jun 2020 23:29:46 +0000 And by "Complaint" I might have meant Indictment. From: (USANYS) Sent: Thursday, June 11, 2020 7:29 PM To: c >; ) ca; Subject: RE: Draft Maxwell Indictment Congratulations on having made it (this far) through the drafting gauntlet! With apologies for the intrusion, any chance once of you could send me a word version of the original Epstein complaint? Thanks very much. From: <Ma Sent: Thursday, June 11, 2020 6:13 PM (USANYS) • USANYS) < >; (USANYS)< <W1SANYS)< > >: (USANYS) Cc: <->; (USANYS) (USANYS) Subject: Draft Maxwell Indictment All, Attached please find draft of the Maxwell indictment. One thing to flag for discussion: The perjury charge in Count Five currently includes Maxwell's testimony about Via. age. Our understanding is that we need to include the full transcript excerpt in the indictment and that, although we can anonymize name, we need to use the same alias (here, "Minor Victim-1") whenever we refer to her in the entire indictment. As a result, anyone who has access to the deposition transcript will be able to identify l=as Minor Victim-1. That would significantly undermine the assurances we have made that we will do everything in our power to protect her identity. Our hope is that either (a) there is a legally permissible way to further anonymize the reference to in that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protectMMidentity. EFTA00078067