EFTA00086658.txt

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

"civil defamation case Virginia [REDACTED] filed in 2015. [REDACTED] claimed that Maxwell defamed her"

"HADDON, MORGAN & FOREMAN P.C. ... Attorneys for Ghislaine Maxwell"

"COHEN & GRESSER LLP ... Attorneys for Ghislaine Maxwell"

"Law Offices of Bobbi C. Stemheim ... Attorneys for Ghislaine Maxwell"

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant"

"defamation action it filed against Maxwell"

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

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

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

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

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

"the parties settled the defamation claim... Maxwell, 325 F. Supp. 3d 428"

"Giuffre v. Maxwell Litigation, including the complaint"

"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)"

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

"Boies Schiller possessed relevant information... David Boies himself apparently approached the government"

"Judge McMahon relied on the Assistant U.S. Attorney's misrepresentations"

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

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

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

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

"the prosecutor... the Assistant U.S. Attorney's personal knowledge"

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

"Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP"

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

"Boies Schiller was among those plaintiff attorneys... in connection with their representation of witnesses or victims"

"the firm had come to the government asking it to open an investigation"

"The government knew what was in the Boies Schiller file; the law firm had provided that information well before the investigation began"

"Count Six... alleges that Maxwell provided false testimony when she testified... she never gave anyone, including Accuser-23, a massage"

"Boies Schiller could comply with the subpoena... Maxwell could not have reasonably relied on the Protective Order as prohibiting Boies Schiller from c"