EFTA00018997.pdf

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

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

"the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP ... the 90,000-sum pages of material it obtained from Boies"

"Giuffre v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018)"

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

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

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

"Giuffre sued Maxwell, not the other way around. And the defamation claim (the only claim Giuffre ever asserted against Maxwell)"

"the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller"

"details about Maxwell that are contained in Boies Schiller's 90,000 pages of confidential material... information about Maxwell's sexual partners, sex"

"Doe v. Indyke, No. 20-cv-484-JLIC, the government intervened and moved to stay discovery"

"allowing the unsealing process to unfold... Judge Preska has refused to unseal all of the testimony charged in the indictment"

"Maxwell did not assert her Fifth Amendment privilege against self-incrimination during that deposition and testified truthfully"

"the Giuffre action"

"Chief Judge McMahon's analysis of Martindell... central to Judge McMahon's decision to modify the Protective Order"

"Judge Preska—who is presiding over the Giuffre action"

"Judge Sweet—who is presiding over the Giuffre action since Judge Sweet's passing"

"David Boies later complained about his frustration... contacts with Boies Schiller"

"the government and Boies Schiller collaborated and that Boies Schiller's conduct was in part at the government's behest"

"Maxwell did not assert her Fifth Amendment privilege against self-incrimination during that deposition"

"dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this Motion."

"Maxwell was deposed over two years before the Government opened its investigation"

"Attorneysfor Ghislaine Maxwell"

"Attorneysfor Ghislaine Maxwell"

"Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016"

"the government misled Chief Judge McMahon to modify the Giuffre Protective Order and authorize the subpoena to Boies Schiller"

"the government's subpoena to Boies Schiller ... to suppress all evidence obtained from the government's subpoena ... in Giuffre v. Maxwell"

"the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosec"

"the government misled Judge McMahon about its contacts with Boies Schiller ... Giuffre produced no such materials"

"the government contemplated a perjury prosecution of Maxwell"

"Boies Schiller met with the government and pressed an investigation for, among other things, perhay"

"Under Judge Sweet's pre-deposition order, Giuffre should have turned these documents over to Maxwell before the April 2016 deposition."

"Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre"

"Boies Schiller was acting as an agent of the state for Fifth Amendment purposes when deposing Maxwell"

"a private party, like Boies Schiller, is deemed to be an agent of the state when the government has provided such significant encouragement"

"Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016"