DOJ-OGR-00002360.pdf

Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 13 of 23 Ex. E, 99 pp 2-3. Those representations were false. At the time the government claims it began the investigation (), its knowledge of the civil case was not based exclusively on public filings. It knew that possessed relevant information because had come to the government asking it to open an investigation. In particular, on February 29, 2016, AUSA Amanda Kramer met with attorneys from Boies Schiller, who “urged Kramer to open an investigation of” Epstein and Maxwell.4 Then, after Maxwell’s two depositions, David Boies himself apparently approached the government in the summer of 2016, asking “if the Southern District would consider charging Maxwell with perjury.” Brown, supra n.2. Said Mr. Boies: “We were saying to anyone who would listen: We’ve got clients who were abused. Some of them were underage. We have the evidence. There’s a whole record that’s been developed. We can establish beyond any reasonable doubt there was a massive sex trafficking ring going on.” Id. 4 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-jmzh17drzdgrbbs7yc6bfnszu-story.html. 8 DOJ-OGR-00002360