DOJ-OGR-00004149.pdf

Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 14 of 34 But in her 2021 interview, AUSA mostly disclaimed a memory of what happened in 2016. Ex. K. The phrases "does not recall," "does not remember," or some similar expression of lack of memory appear at least thirty-two times in the notes of the government’s 2021 call with AUSA . Id. Many of AUSA disclaimers, however, are simply not credible. For example, AUSA claimed not to “have an independent memory of the Giuffre v. Maxwell [defamation] lawsuit being mentioned” during the meeting, id. at 1, even though her notes are replete with references to the lawsuit, Ex. J. After reviewing her notes, AUSA denied that they refreshed her memory. Ex. K, p 1. AUSA similarly denied remembering whether Giuffre’s attorneys ever provided her with documents, id. at 6, despite the email from Peter Skinner just hours after the February 29 meeting providing AUSA with numerous documents, Ex. L, p 1-2, and despite the fact that AUSA in 2018 personally delivered those documents to AUSA , and one member of the prosecution team in this case, Ex. N, p 1 (12/6/2018 Email to AUSA : “Just went through my files and found a folder w/ the notes I took and the documents they brought me. Want to come by?”). When AUSA did claim to remember what transpired, her memory was often inconsistent with the contemporaneous evidence. Take just one example. “To [her] knowledge,” AUSA said, she did “not receive[] any discovery materials from any civil case.” Ex. K, p 6. That is not correct. The government admits that AUSA received from Giuffre’s attorneys, and turned over to AUSA and others in the office, including flight records and Palm Beach Police Department Records. Resp. at 66 & n.2. Both of these documents were produced in discovery in the civil case. 9 DOJ-OGR-00004149