📧 Communication

This document is page 12 of a legal filing (Case 1:20-cr-00330-AJN) filed on January 25, 2021. The defense argues that Perjury Counts should not be joined with Mann Act Counts because the alleged false statements occurred during 2016 civil depositions regarding a defamation suit (involving Virginia Giuffre) and were not made to the FBI or a grand jury to thwart an existing investigation. The text references a purported conspiracy between Maxwell and Epstein from 1999-2002.