From: To: Ce: ~My ms Subject: Draft Maxwell Indictment Date: Thu, 11 Jun 2020 22:12:47 +0000 Attachments: 2020-06-11, Maxwell, draft indictment.docx 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 obo age. Our understanding is that we need to include the full transcript excerpt in the indictment and that, although we can anonymize ame, 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 identif 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 n that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protec {EE dentity. Thanks EFTA00078066