DOJ-OGR-00004147.pdf

Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 12 of 34 the significance of those interactions and of AUSA misrepresentations to an Article III federal judge. This Court should not permit the government to whitewash its conduct. The discovery provided to Maxwell in response to her Motion rebuts every defense the government now offers of its conduct. And if that weren't enough, the government's defense fails on its own terms, because if this Court were to assume its truth (an assumption the government has not earned), AUSA statements to Judge McMahon would still have been demonstrably and materially false. A. The Government's Defenses Are Not Credible. Discovery provided to Maxwell in response to her Motion rebuts every defense the government now offers of its conduct. Defense 1: The February 29, 2016 meeting was only about Epstein. AUSA contemporaneous hand-written notes entirely undermine the government's claim that the February 29, 2016 meeting was about Epstein only and had nothing to do with Maxwell. Resp. at 89 & n.39. See Ex. J. AUSA notes refer to Maxwell as Epstein's "head recruiter" of underage girls; they document allegations that Maxwell "regularly" took sexually explicit photos of Giuffre and other underage girls, which she kept on her computer; they allege that Maxwell gave one such photo to Epstein as a birthday present, which he hung on his wall; they claim that Maxwell, along with Epstein, brought Giuffre to New York to personally "train[] [her] . . . [in] how to service men;" and they assert that Maxwell used the "same MO" to recruit other girls to the sex trafficking scheme. The contents of AUSA notes belie any notion that Giuffre's attorneys—who at that very moment were suing Maxwell 7 DOJ-OGR-00004147