Subject: RE: Draft Maxwell Indictment¶
Date: Thu, 11 Jun 2020 23:29:46 +0000¶
And by “Complaint” I might have meant Indictment.¶
Subject: RE: Draft Maxwell Indictment¶
Congratulations on having made it (this far) through the drafting gauntlet! With apologies for the intrusion, any chance once of you could send me a word version of the original Epstein complaint? Thanks very much.¶
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 about Nadia age. Our understanding is that we need to include the full transcript excerpt in the indictment and that, although we can anonymize by 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 identify as Minor Victim-1. That would significantly undermine the assurances we have made 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 in that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protect identity.¶
EFTA00078067¶
Attached. Please note to him that the complaint contains some inconsistencies both with incontrovertible facts (for example, her age when she met Epstein) and with her descriptions to us (for example, a vague reference to threats, references to frequent flights that both and Maxwell took on the jet, and certain references to her age at the time of certain events).¶
Do you have any sense of what he’s looking for (or at) in particular?¶
Do you guys have a copy of her Jane Doe civil complaint? If so, would like a copy, so would you mind sending on? Thanks¶
EFTA00078070¶