From: To: Ce: <] > (USANYS)' Subject: RE: Draft Maxwell Indictment Date: Fri, 12 Jun 2020 21:16:27 +0000 Attachments: 2020-06-11 Maxwell draft_indictmentLGB.docx Hi all, Thanks for circulating. | had some preliminary, high level comments, reflected in the attached. Perhaps we could set up a time next week to talk these through? Have a great weekend. Fro: TS <i Sent: Thursday, June 11, 2020 6:13 PM ee oe — a (usANys) <i; ( USANYS) SNR USANYS) < ; SN (USANYS) > a LS <<: ES SANS) A; a (SAYS) <r Subject: Draft Maxwell Indictment 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 ge. Our understanding is that we need to include the full transcript excerpt in the indictment and that, although we can anonymize name, we need to use the same alias (here, “Minor Victim-1”) whenever we refer to her in the entire indictment. It, anyone who has access to the deposition transcript will be able to identify ma: Minor Victim-1. That would significantly undermine the assurances we have made il ht 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 toM(@™@Min that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protect |g identity. Thanks, EFTA00090550