EFTA00029816.pdf

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

"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. Sternheim... Attorneys for Chislaine Maxwell"

"Sealed Order (19 Misc. 149 (CM))"

"Maxwell's April and July 2016 depositions"

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

"v. Maxwell, a civil defamation case filed in 2015"

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

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

"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"

"sexual activities at Epstein's Palm Beach house"

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

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

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

"Magistrate Judge Netburn rejected an identical request from the government in a different civil case"

"Maxwell-on the ground that the government simply had too little knowledge of what was in the law firm's files to craft a more narrowly tailored subpoe"

"Dismiss Counts Five and Six, Which Are The Fruits Of That Evidence"

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

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

"Maxwell likewise relied on the Protective Order in choosing to render such intimate details, rather than assert her Fifth Amendment privilege"

"Attorneys for Ghislaine Maxwell"

"Attorneys for Ghislaine Maxwell"

"dismiss Counts Five and Six"

"the government made its misrepresentations to Judge McMahon"

"suppress all evidence the government obtained from Boies Schiller"

"The prosecutor's office is an entity and as such it is the spokesman for the Government."

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

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

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

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

"cause to be sexually abused and trafficked by Jeffrey Epstein"

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

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

"urged Kramer to open an investigation of Epstein and Maxwell"

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

"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"

"the law firm had provided that information well before the investigation began. The government did indeed have previous contact with (the trml."

"We've got clients who were abused. Some of them were underage. We have the evidence."

"Boies Schiller did foment the investigation (or at least it tried to). And the evidence of collusion between the government and Boies Schiller was amp"

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

"see also Giglio v. U.S., 405 U.S. 150, 154 (1972) ("The prosecutor's office is an entity...")"