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scovery in this matter ends in less than two months, and we respectfully submit that her delay tactics should end now. Respectfully submitted, /s/ David Boies David Boies, Esq. cc: Counsel of Record (via ECF) 2 Maxwell also argues that the fact that Plaintiff's sister (and a few other victims) have volun
ment 72 Filed 05/18/20 Page 1 of 3 BSF VIA ECF BOIES SCHILLER FLEXNER The Honorable Debra C. Freema
of the criminal investigation into Epstein's co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation. When Plaintiff's counsel asked Maxwell's counsel for information about the criminal investigation during their meet and confer, Maxw
omments, which serve no compelling law enforcement or investigatory purpose, are prohibited by the local rules of this District. New York attorney David Boies and his partner Sigrid McCawley, who represent several witnesses in this matter, have also made public and presumptively prejudicial statements in
practicing in this District, generally, and lawyers for witnesses, specifically. See Rule 23.1(a) and (b). As reported by the Washington Post, Mr. Boies expressed his views on the prohibited subject of "the possibility of a plea of guilty to the offense charged or a lesser offense" in violation of s
of the criminal investigation into Epstein's co-conspirators. the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation," Boies wrote. Epstein investigators contacted by 'dozens' since his death EFTA00075115 Caselta52/1435/11.1SlotRmDittctidienOICM
of the criminal investigation could impair her Fifth Amendment privilege against self-incrimination: added her attorney, Laura Menninger. attorney, David Boies, noted in his response that Maxwell has not publicly admitted she herself is the center of a federal investigation, but is nevertheless using it to
in's co-conspirators. the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation," Boies wrote. Epstein investigators contacted by 'dozens' since his death EFTA00084378 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 14 o
of the criminal investigation into Epstein's co-conspirators. the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation," Boies wrote. Epstein investigators contacted by 'dozens' since his death EFTA00084378 Case 1:15-cv-07433-LAP Document 1078-5 F
Entities connected to both David Boies and the Southern District's

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Paul Cassell
PERSON
Virginia Giuffre
PERSON
United States
LOCATIONJane Doe
PERSON
Bill Clinton
PERSONLeon Black
PERSONJeffrey Pagliuca
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
New York
LOCATION
Michael Cohen
PERSON
Harvey Weinstein
PERSON