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provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00077730 behavior by a private party seeking to secure evidence against a
provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge
eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00039545 behavior by a private party seeking to secure evidence against a
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma
as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7
al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted
osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New
her assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori
t privilege is not concerned `with moral and psychological pressures to confess emanating from sources other than official coercion.'" Id. (quoting Elsiad, 470 U.S. at 305). For this reason, even "[t]he most outrageous 98 EFTA00095190 behavior by a private party seeking to secure evidence against a
Entities connected to both Ghislaine Maxwell and Elsiad

Jeffrey Epstein
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONDoug Band
PERSONJane Doe
PERSON
David Boies
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
Palm Beach
LOCATION
Colorado
LOCATION
Scarlett Johansson
PERSON
United Kingdom
LOCATIONMartin Weinberg
PERSON
Southern District of New York
ORGANIZATION