EFTA00090550.pdf

From:' (USANYS)" To:' rH Cc: (USANYS)" (USANYS)" Subject: RE: Draft Maxwell Indictment Date: Fri, 12 Jun 2020 21:16:27 +0000 Attachments: 2020-06-11 Maxwell_draft_indictmentLOB.docx Hi all, Thanks for circulating. I had some preliminary, high level comments, reflected in the attached. Perhaps we could set up a time next week to talk these through? Have a great weekend. From: Sent: Thursday, June 11, 2020 6:13 PM To: (USANYS) (USANYS) < (USANYS) < >; USANYS) < >;' (USANYS) Cc: >:1 <->; (USANYS) <I >; (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 Mt ge. Our understanding is that we need to include the full transcript excerpt in the indictment and that, a t ough we can anonymize name, we need to use the same alias (here, "Minor Victim-1") whenever we refer to her in the entire indictment. lt, anyone who has access to the deposition transcri t will be able to identify a Minor Victim-1. That would significantly undermine the assurances we have made hat we will do everything in our power to protect her identity. Our hope is that either (a) there is a legally permissi le way to further anonymize the reference toliallin that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protect identity. Thanks, EFTA00090550