EFTA00029077.pdf

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

"defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y)."

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

"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."

"Judge Netburn Separately Rejects An Identical Gambit By The Government"

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

"claimed that Maxwell defamed her when Maxwell's attorney-hired press agent denied as untrue and obvious lies numerous allegations"

"Maxwell declined to invoke her privilege against compulsory self-incrimination and agreed to testify at her April 2016 deposition."

"Maxwell appeared at a second deposition, in July 2016. and answered hundreds of pages worth of questions"

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

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

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

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

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

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

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

"information regarding the [ v. Maxwell] Litigation... Maxwell could not have reasonably relied on the Protective Order"

"Attorneysfor Chislaine Maxwell"

"Attorneysfor Chislaine Maxwell"

"dismiss Counts Five and Six"

"Assistant U.S. Attorney did not discharge that basic function... submitted on behalf of the office he serves"

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

"Mark S. Cohen... OHEN & GRESSER LLP"

"dismiss Counts Five and Six, which are the fruits of that evidence"

"The Maxwell depositions sought highly intrusive evidence of the most personal aspects of Maxwell's life."

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

"The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution."

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

"Boies Schiller had in fact approached the prosecutors multiple times well before the grand jury subpoena issued... met with attorneys from Boies Schil"

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

"ongoing Investigation of Jeffrey Epstein... investigation began on either November 30 or December 3, 2018"

"Judge McMahon's ruling to amend the Protective Order was based on the government's misrepresentations."

"in what should have been a simple defamation case-Boies Schiller expressly invoked the assurances of the Protective Order"

"the government's secret, ex parte application... to overcome the parties' reasonable reliance on the Protective Order"

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

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

"Boies Schiller did foment the investigation... designed to have Maxwell charged with perjury"

"discovery of whether Boies Schiller shared actual sealed materials or the contents of sealed materials during its meetings with the United States Atto"

"Judge McMahon's ruling to amend the Protective Order was based on the government's misrepresentations."

"Boies Schiller had previously approached his office... in an effort to stir up a criminal prosecution and dangled the deposition transcripts as a carr"

"Boies Schiller was among those plaintiff attorneys... in connection with their representation of witnesses or victims... in [ v. Maxwell] Litigation"