EFTA00078066.pdf

From: To: ' SANYS)" SANYS)" USANYS)" , "Graff, Ilan (USANYS)" Cc: (USANYS)" (USANYS)" Subject: Draft Maxwell Indictment Date: Thu, 11 Jun 2020 22:12:47 +0000 Attachments: 2020-06-11,_Maxwell,_dratindictment.docx 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 abou age. 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. As a result, anyone who has access to the deposition transcript will be able to identiaas Minor Victim-1. That would significantly undermine the assurances we have madeMt 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 n that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protec dentity. hanksin S EFTA00078066