EFTA00028929.pdf

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

"Defendant's Response in opposition to Motion to Exceed Presumptive Ten Deposition Limit, v. Maxwell, No. 15-cv-07433-RWS"

"Jeffrey S. Pagliuca... Attorneysfor Ghislaine Maxwell"

"Laura A. Menninger... Attorneysfor Ghislaine Maxwell"

"Handwritten Notes by AUSA of Meeting and Contacts with Peter Skinner, Stan Pottinger, and Brad Edwards"

"Handwritten Notes by AUSA of Meeting and Contacts with Peter Skinner, Stan Pottinger, and Brad Edwards"

"Email from Stan Pottinger to AUSA cc'ing Brad Edwards and Sigrid McCawley, re Daniel Siad (Mar. 3, 2016)"

"grand jury subpoena it issued to Boies Schiller Flexner LLP"

"a prosecutor from the public corruption unit of the United States Attorney's Office"

"to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena"

"That Maxwell was Epstein's head recruiter of underage victims."

"That M was live in sex slave from 2000-2002."

"That M was underage when she was brought to New York for training by Maxwell and Epstein in how to service men."

"That M had a pending civil lawsuit against Maxwell for defamation alleging that Maxwell had recruited M to be trafficked and abused by Epstein."

"Peter Skinner of Boies Schiller... who represented M"

"after the February 29, 2016 meeting with attorneys. . . AUSA certainly did not deny a second meeting"

"attorneys—who at that very moment were suing Maxwell for defamation for denying she had trafficked and abused"

"AUSA in 2018 personally delivered those documents to AUSA [REDACTED-002] and one member of the prosecution team"

"When AUSA appeared before Judge McMahon barely four months later, however, he told her none of this"

"AUSA unquestionably should have told Judge McMahon about the February 2016 meeting when she asked him about contacts between the United States Attorne"

"Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files"

"AUSA even mentioned this concern to the Chief of the Criminal Division."

"Judge McMahon's meaning... in her written order authorizing the subpoena [related to Maxwell's motion]."

"Maxwell also had a privacy interest in the materials subject to the subpoena, including most especially her deposition transcripts [held by Boies Schi"

"Judge McMahon wrongly concluded that Maxwell could not have reasonably relied on the Protective Order."

"Judge Netburn denying the government's ex parte request to modify the Jane Doe 43 Protective Order in part because the government was attempting to de"

"The Second Circuit in ... v. Maxwell held a few months after Judge McMahon's ruling that Maxwell had reasonably relied on the Protective Order's guara"

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

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

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

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

"dismiss Counts 5 and 6"

"dismiss Counts 5 and 6"

"AUSA notes say... they say nothing of the sort about Maxwell"

"Judge McMahon haled AUSA back to court. ... I'll be very up-front with you, she said."

"government issued two subpoenas to Boies Schiller: the first for material covered by the Protective Order, and the second for material outside the Pro"

"Among others, the article quotes David Boies, who said: We were saying to anyone who would listen: We've got clients who were abused."

"AUSA [redacted] still denied that Boies Schiller had any role in fomenting the investigation and claimed that there had been no contacts between Boies"

"AUSA notes refer to Maxwell as Epstein's head recruiter of underage girls"

"the U.S. Attorney's Office had sustained contact with Boies Schiller in 2016. . . attorneys pitched a prosecution of Maxwell and Epstein"

"email from Peter Skinner just hours after the February 29 meeting providing AUSA with numerous documents"

"they say nothing of the sort about Maxwell, instead describing her as Epstein's head recruiter"

"Judge McMahon haled AUSA back to court ... I would like to know about contacts between the United States Attorney's Office and the Boies Schiller firm"

"AUSA still misled Judge McMahon and misrepresented the origins of the investigation. Under the government's version of events, the pitch was to invest"

"AUSA misled her, it is clear Judge McMahon would not have authorized the subpoena... AUSA misled Judge McMahon in answering the singular question she "

"suppress all evidence the government obtained from Boies Schiller and any other evidence derived therefrom"

"AUSA admitted that she contemplated a perjury prosecution, and she recalls thinking that a perjury investigation would have ... challenges."

"the defamation suit against Maxwell was on-going—as part of an effort to instigate a criminal prosecution of Maxwell"

"Maxwell, along with Epstein, brought to New York to personally train her . . . [in] how to service men"

"that [REDACTED-002] or her lawyers [Boies Schiller] would not do what the defendant in Chemical Bank did"