Epstein Secrets

ed 03/30/21 Page 1 of 7 BSF Sigrid S. McCawley BOIES SCHILLER FLEXNER March 22, 2021 VIA EMAIL (FI

tion of any kind," and defines "You" as "any owner, shareholder, partner or employee of Boies, Schiller, Flexner, LLP, including but not limited to David Boies, Sigrid McCawley, Peter Skinner and any former owner, shareholder, partner or employee, or independent contractor of the firm." Such broad Requests

uthorizing service of the Subpoena on BSF. The Court, however, should exercise its discretion and deny the Defendant's motion. See United States v. Weissman, No. 01 Cr. 529 (BSJ), 2002 WL 1467845, at *1 (S.D.N.Y. July 8, 2002) ("Rule 17(c) expressly commits the decision whether to require pre-trial produ

following: Sigrid S. McCawley Meredith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boule

ts designated their indemnification agreement as confidential does not shield it from discovery"); Tribune Co. v. Purciglioni, 1996 WL 337277 at •3; Weissman v. Fruchtman, 1986 WL 15669,'19 (S.D.N.Y.1986) ("parties' intention that agreement remain confidential is not controlling."). In sum, a third-party

ord including the following: Sigrid S. McCawley Boies, Schiller & Flexner, LLP East Las Olas Boulevard

malice. Pl.'s Opp'n at 7-9. In any event, contrary state cases cited by Plaintiff contained more than conclusory allegations of malice. Karachi v. Weissman, 1 N.Y.S.3d 169, 182 (2d Dep't 2014) (complaint sufficiently alleged malice supported by statements undermining Rabbi's authority and statements ref