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Extraction Summary

5
People
3
Organizations
0
Locations
3
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 793 KB
Summary

This legal document describes a February 2016 meeting where attorneys presented information to an Assistant U.S. Attorney (AUSA-1) about individuals connected to Epstein, with a focus on Maxwell. It asserts that because this meeting pre-dated the depositions central to the current indictment, the attorneys could not have alleged perjury related to those specific depositions at that time. The document also notes AUSA-1's lack of recall regarding specific perjury discussions involving Maxwell and details the government's subsequent review of AUSA-1's emails for related communications.

People (5)

Name Role Context
Epstein
Mentioned as someone who had individuals working for and/or helping him.
Maxwell
Mentioned as an individual who worked for/helped Epstein and was the subject of a potential perjury investigation.
AUSA-1 Assistant U.S. Attorney
An Assistant U.S. Attorney who met with attorneys in February 2016, received emails, and whose archived emails were s...
David Boies Attorney
An attorney whom AUSA-1 has never met. Associated with the law firm Boies Schiller.
Pottinger Attorney
An attorney who sent an email to AUSA-1 on May 3, 2016, suggesting a telephone conversation occurred on May 2, 2016.

Organizations (3)

Name Type Context
USAO-SDNY government agency
The U.S. Attorney's Office for the Southern District of New York, where AUSA-1 worked until 2019. The attorneys prese...
The Government government agency
Refers to the U.S. Government/prosecution, which conducted a review of AUSA-1's emails and is producing them to defen...
Boies Schiller company
A law firm mentioned in a footnote. The Government searched for email communications with attorneys from this firm.

Timeline (3 events)

2016-02
Attorneys met with AUSA-1 to discuss individuals who worked for Epstein, focusing on Maxwell. They did not suggest specific criminal statutes or investigative steps.
AUSA-1 attorneys
2019
AUSA-1 left the USAO-SDNY.
USAO-SDNY
The Government conducted a review of AUSA-1's archived emails to find communications with attorneys from Boies Schiller and others from the February 2016 meeting.

Relationships (3)

AUSA-1 professional David Boies
The document explicitly states that AUSA-1 "has never met David Boies."
AUSA-1 professional Pottinger
Pottinger sent an email to AUSA-1 and they may have spoken by telephone, indicating a professional contact.
Maxwell professional Epstein
The document states that attorneys referenced "multiple individuals who worked for and/or helped Epstein, including Maxwell".

Full Extracted Text

Complete text extracted from the document (2,356 characters)

Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 90 of 239
4 at 1, 4). During the meeting, the attorneys referenced multiple individuals who worked for and/or helped Epstein, including Maxwell, but the attorneys primarily focused their presentation on Epstein. (See id. at 1-2, 4). The attorneys did not present particular criminal statutes that might be pursued by the USAO-SDNY or make suggestions about investigative steps, nor did they suggest the use of civil lawsuits as a means to conduct a criminal investigation. (Id. at 2-3). AUSA-1 did not tell the attorneys whether or not an investigation would be opened, consistent with her standard practice. (Id. at 3). After the meeting, AUSA-1 received a limited number of emails from the attorneys (see Exs. 6 & 7).30 AUSA-1 did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4).
AUSA-1 recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed or the substance of the depositions. (Id. at 5). AUSA-1 does recall thinking through the challenges of a potential perjury investigation, but she does not recall who specifically would have been he target of such an investigation. (Id.). AUSA-1 does not recall being asked if the USAO-SDNY would consider charging Maxwell with perjury. (Id.). Moreover, and critically for present purposes, the meeting described above pre-dated the depositions which give rise to the perjury counts in the instant Indictment, making it all but impossible that the attorneys suggested, during that February 2016 meeting, that Maxwell had committed perjury in depositions that, as detailed below, had yet to occur.
The Government has also conducted a review of AUSA-1’s emails in an effort to determine whether any further contacts occurred. One email dated May 3, 2016 from Pottinger to AUSA-1 appears to suggest that AUSA-1 spoke with Pottinger on or about May 2, 2016 by telephone (see
30 AUSA-1 left the USAO-SDNY in 2019. Since receiving the Defense Motions, the Government has searched AUSA-1’s archived emails for any email communications with attorneys from Boies Schiller or the other attorneys who participated in the February 2016 meeting. The Government is producing all identified emails to defense counsel today.
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DOJ-OGR-00003024

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