Epstein Secrets

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!I

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury' (

tered on multiplicitous counts, that right is protected by vacating the convictions on all but one count. Id. The Second Circuit has clarified that District Courts should not rule on a motion to dismiss a charge on multiplicity grounds until the time of sentencing. See id. (vacating district court's 170 EFTA0

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking if the Southern District would consider charging Maxwell with perjury"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

tered on multiplicitous counts, that right is protected by vacating the convictions on all but one count. Id. The Second Circuit has clarified that District Courts should not rule on a motion to dismiss a charge on multiplicity grounds until the time of sentencing. See id. (vacating district court's 170 EFTA0

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking if the Southern District would consider charging Maxwell with perjury"' (

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

tered on multiplicitous counts, that right is protected by vacating the convictions on all but one count. Id. The Second Circuit has clarified that District Courts should not rule on a motion to dismiss a charge on multiplicity grounds until the time of sentencing. See id. (vacating district court's 170 EFTA0

rtindell standard. "circ --- it cited 11 times in its argument to both relevant courts. (See (Exs. 8 Instead, the Government issued a subpoena to Boies in connection with its investigation, and made an application to two judges to modify Rule 26(c) protective orders that precluded full compliance

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury' (

tered on multiplicitous counts, that right is protected by vacating the convictions on all but one count. Id. The Second Circuit has clarified that District Courts should not rule on a motion to dismiss a charge on multiplicity grounds until the time of sentencing. See id. (vacating district court's dismissal

ot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that "after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking `if the Southern District would consider charging Maxwell with perjury"'

y contrast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. A

tered on multiplicitous counts, that right is protected by vacating the convictions on all but one count. Id. The Second Circuit has clarified that District Courts should not rule on a motion to dismiss a charge on multiplicity grounds until the time of sentencing. See id. (vacating district court's 170 EFTA0

016, I electronically served this DEFENDANT'S REPLY IN FURTHER SUPPORT OF MOTION FOR PROTECTIVE ORDER via ECF on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 Is/ Nicole Simmons Nicole Simmons 9 EFTA00622054

neither. The Protective Order offered by Ms. Maxwell is neutral, understandable, and enforceable. It is the type of order routinely entered in U.S. District Courts and should be entered in this case. 8 EFTA00622053 Case 1:15-cv-07433-RWS Document 49 Filed 03/09/16 Page 12 of 12 Dated: March 9, 2016 Respect