EFTA00011452.pdf

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (MN)"

"Jeffrey S. Pagliuca ... Attorneys for Ghislaine Maxwell"

"Laura A. Menninger ... Attorneys for Ghislaine Maxwell"

"Mark S. Cohen ... Attorneys for Ghislaine Maxwell"

"Christian R. Everdell ... Attorneys for Ghislaine Maxwell"

"Bobbi C. Stemheim ... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca HADDON, MORGAN & FOREMAN P.C."

"Mark S. Cohen COHEN & GRESSER LLP"

"v. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y)"

"the government issued a grand jury subpoena for Boies Schiller's file"

"instituted an ex parte proceeding before Chief Judge McMahon to modify the Protective Order."

"v. Maxwell, a civil defamation case filed in 2015. claimed that Maxwell defamed her"

"Counts Five and Six of the superseding indictment allege that Maxwell committed perjury during two civil depositions"

"her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein"

"In 2017, the parties settled the defamation claim, and the case was dismissed."

"On February 29, 2016, AUSA met with attorneys from Boies Schiller, who urged to open an investigation of Epstein and Maxwell"

"Boies Schiller produced some 90,000 pages of discovery material to the government, including both of Maxwell's deposition transcripts."

"the government had instituted an ex parte proceeding before Judge McMahon, Case No. 19-Misc.-149 (CM) (S.D.N.Y)."

"the request for information in part for exactly the reasons that you describe. We have either little or no additional information than the Court does "

"Magistrate Judge Netbum rejected an identical request from the government in a different civil case, Jane Doe 43 v. Epstein"

"the government to investigate and prosecute Maxwell"

"Jane Doe 43 v. Epstein, Case No. 17-cv-616 (JGK) (SN)."

"the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victims"

"Attorneysfor Chislaine Maxwell"

"Attorneysfor Chislaine Maxwell"

"served by email ... the Memorandum of Ghislaine Maxwell ... upon the following: U.S. Attorney's Office, SDNY"

"dismiss Counts Five and Six"

"Boies Schiller produced some 90,000 pages of discovery material to the government, including both of Maxwell's deposition transcripts."

"Judge McMahon never would have permitted the circumvention of the civil Protective Order"

"We reference them here only to show their connection to the perjury counts that the government subsequently charged."

"Boies Schiller shared actual sealed materials or the contents of sealed materials during its meetings with the United States Attorney's Office in 2016"

"Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients."

"Maxwell had participated in a scheme to cause to be sexually abused and trafficked by Jeffrey Epstein"

"Maxwell discussed the intimate details of her sexual activity with Epstein"

"David Boies himself apparently approached the government in the summer of 2016, asking if the Southern District would consider charging Maxwell with p"

"Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, "

"Judge McMahon modified the Protective Order so that Boies Schiller could comply with the subpoena."

"Boies Schiller was all too eager for the government to investigate and prosecute Maxwell"

"The Maxwell depositions sought highly intrusive evidence of the most personal aspects of Maxwell's life. ... Boies Schiller expressly invoked the assu"

"Judge McMahon held a hearing with the sole purpose of asking the prosecutor, point blank, about the government's contacts with Boies Schiller."

"The Maxwell depositions sought highly intrusive evidence... in what should have been a simple defamation case"

"the extent to which the prosecutor's office had, in fact, coordinated with Boies Schiller prior to the issuance of the grand jury subpoena"

"before and after the Maxwell depositions... suppress the April and July 2016 depositions"

"The government lawyer assured Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file... Maxwell alleges every word of the go"

"attorneys asked Maxwell whether Jeffrey Epstein [had] a scheme to recruit underage girls for sexual massages"

"the government's misrepresentation to Judge McMahon was not simply related to Counts Five and Six"

"Boies Schiller had previously approached his office... and dangled the deposition transcripts as a carrot"