DOJ-OGR-00014150.pdf

--- Page 1 --- The extracted text is: **Case 1:20-cr-00330-PAE** **Document 763** **Filed 08/10/22** **Page 44 of 197** **LCHVMAX2** **2585** **if this was now appropriate line of cross.** **THE COURT: No.** **MR. EVERDELL: Understood, your Honor. Okay.** **Then there are two other issues then. I did want to get into this with this witness, that the investigation of the allegations against Ms. Maxwell started with the first three of the accusers, and that time period was focused, so that's Jane, Annie Farmer, and Kate. And that time period was focused on '94 to '97. And then they got an indictment based on those charges. And then later, they talked to Carolyn and they amended the indictment, and those allegations relate to a later time period, 2001 to 2004, and that those are the subject of the last two counts in the indictment, Counts Five and Six.** **The purpose of this, your Honor, is just to be able to show the jury that there are -- there's a difference between those counts and who the witnesses are, information whose evidence is related to those counts. And I think that's relevant to be able to explain that to the jury without getting -- it doesn't really talk about investigative steps; it's just simply saying, You talked to Carolyn after you spoke to these three first. These are the three who you originally had evidence from against Ms. Maxwell. Carolyn came to you later. You spoke to her first in 2019; she wanted to talk to you with a lawyer. You didn't speak to her again until a year later. At that point you did meet with her. You took her SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014150**