Epstein Secrets

t the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions. Id. at 21

SA mislead Judge McMahon, Maxwell fully and completely quotes Judge McMahon's question, just as she does above. Mot. at 13 (quoting Ex. E, p 2). " United States Department of Justice, JUSTICE MANUAL, JM § 9-11.151, Grand Jury, Advice of "Rights" of Grand Jury Witnesses (updated Jan. 2020), available at: https://www.justice.govijm

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

ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, , subsequently sent the CEOS Chief a draft of the NPA, the

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

ief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted. November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62.6 However, although the line prosecutor, Maria Villafalia, subsequently sent the CEOS Chief a draf