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ection 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As further discussed below, the materials are currently subject to a protective order issued by this Court.
LLP, in connection with the matter of Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As furth
& Flexner LLP, in connection with the matter of Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.).
is permitted to provide the Government with copies of materials generated, received, obtained, or otherwise possessed in connection with case V . Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS), including discovery materials marked "CONFIDENTIAL" pursuant to the protective order dated March 18, 2016. Boies Schil
ade defamatory statements denying that the plaintiff was a victim of sex crimes perpetrated by Jeffrey Epstein and Ghislaine Maxwell, among others (the "Litigation"). Attorneys for Boies Schiller & Flexner LLP, among others, represent the plaintiff. On or about March 18, 2016, this Court issued a protective or
ion 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of v. Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As further discussed below, the materials are currently subject to a protective order issued by this Court.
P is permitted to provide the Government with copies of materials generated, received, obtained, or otherwise possessed in connection with case v. Ghislaine Maxwell, et al., 15 Civ. 7433 (RWS), including discovery materials marked "CONFIDENTIAL" pursuant to the protective order dated March 18, 2016. Bo
ted to provide the Government with copies of materials generated, received, obtained, or otherwise possessed in connection with case v. Ghislaine Maxwell, et al., 15 Civ. 7433 (RWS), including discovery materials marked "CONFIDENTIAL" pursuant to the protective order dated March 18, 2016. Boies Schil
ade defamatory statements denying that the plaintiff was a victim of sex crimes perpetrated by Jeffrey Epstein and Ghislaine Maxwell, among others (the "Litigation"). Attorneys for Boies Schiller & Flexner LLP, among others, represent the plaintiff. protective Protective On or about March 18, order (the "Pr
651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the G
nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page
simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA00066435 Page 4 Martin
in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et al. ("M"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has s
nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district cour
simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). EFTA00084803 Page 4 Martindell, the district court opined
covery materials in the possession of Boies Schiller & Flexner LLP the "A in connection with the matter v. Ghislaine Maxwell, et al. (a), (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
51, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Gov
nformation simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA0
simply as "information that is confidential and implicates common law and statutory privacy interests of (a) plaintiff and (b) defendant Ghislaine Maxwell" and making no reference to trade secrets or other confidential business information). CONFIDENTIAL SDNY_GM_00000849 EFTA_00114933 EFTA01263242
s in the possession of Boies Schiller & Flexner LLP (the "A in connection with the matter v. Ghislaine Maxwell, et at (a"), 15 Civ. 7433 (RWS) (the "Litigation"), a copy of which is enclosed as Exhibit A. Background As described in the Application, the Government has served a grand jury subpoena (the "Subp
By 2021, our firms had successfully brought lawsuits against Epstein himself during his life, his estate after his death, certain collaborators like Ghislaine Maxwell, and certain participants like Prince Andrew. Although we had collectively recovered substantial amounts for our clients, we believed they had not
ove, Ms. McCawley has devoted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of G
Cawley has devoted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of Ghislaine
ase Bank, N.A. ("Defendant" and together with Plaintiff, the "Parties"). Our firms represent the Class Representative in the above-captioned action (the "Litigation"). A. Preparation of this Case 5. This case grew out of our firms' long representation of the survivors of Jeffrey Epstein's sex trafficking ring.
Entities connected to both Ghislaine Maxwell and the "Litigation"

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Donald Trump
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONDarren Indyke
PERSONJane Doe
PERSON
David Boies
PERSONSigrid McCawley
PERSON
Kenneth Marra
PERSON
Woody Allen
PERSONJack Goldberger
PERSON
Geoffrey S. Berman
PERSONBates
PERSON
Palm Beach County
LOCATION