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opened its investigation and remained ongoing after the Indictment in this case was filed.23 The defendant quotes the Government's letter to Judge Freeman requesting permission to intervene and stay Doe v. Indyke (see hi.), but omits the portion of that letter in which the Government explained that, as
r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t
opened its investigation and remained ongoing after the Indictment in this case was filed.23 The defendant quotes the Government's letter to Judge Freeman requesting permission to intervene and stay Doe v. Indyke (see id.), but omits the portion of that letter in which the Government explained that, as
bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec
counsel for information about the criminal investigation during their meet and confer, Maxwell's counsel refused to provide any details," he added. Freeman agreed Maxwell could potentially incriminate herself by giving a deposition and ordered that she not be required to sit for one as part of the suit.
fight with Epstein's alleged victims long before her recent arrest. "(Maxwell' has been using this Court as a sword and a shield for many years." Schiller wrote in a filing earlier this year, "and she, Jeffrey Epstein, and their other co-conspirators have attempted to thwart their victims from obtaini
Entities connected to both Freeman and Schiller

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
George W. Bush
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSON
Michael Jackson
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
United States
LOCATIONMaria Farmer
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONLeon Black
PERSONEmmy Taylor
PERSON