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Case 1:20-cr-00330-PAE Document 391 Filed 10/29/21 Page 4 of 11

INTRODUCTION

The S2 Indictment alleges that Ms. Maxwell committed the charged crimes between 1994 and 2004. Accusers -1, -2 and -3 purportedly were abused between 1994 and 1997. Accuser 3 is alleged, in the Indictment, to have had contact with Jeffrey Epstein between 2001 and 2004, [REDACTED].

The Government has listed a series of exhibits allegedly obtained during an October 2005 search of Epstein’s Palm Beach residence, 358 El Brillo Way. The Court should prohibit the introduction of any item seized during the search because of serious questions about how and where the evidence was maintained, the lack of any authenticating witness, and the lack of relevance to the charges against Ms. Maxwell.

I. The Palm Beach Investigation

Ms. Maxwell was never a target or focus of any investigation undertaken by the Palm Beach Police Department, ever. Not one of the witnesses contacted during the investigation identified Ms. Maxwell as a person who recruited them, had contact with them, or instructed them to do anything with Epstein.

The reports from the Palm Beach Police Department reflect that Officer [REDACTED] received an anonymous complaint about an unidentified male on March 14, 2005. Officer [REDACTED] began an investigation that, six months later, was turned over to officer Joseph Recarey. Officer [REDACTED] investigative efforts centered on an alleged victim [REDACTED], according to the police reports, was contacted at her school as a result of a concern by her stepmother. When questioned at the school, [REDACTED] denied any sexual contact with any adult male. Later she acknowledged having sexual contact with Epstein and also told the police that she told Epstein that she was 18 years old. She indicated that she met Epstein through an individual named [REDACTED] and also

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