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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
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
Filed 07/29/20 Page 1 of 10 EXHIBIT D EFTA00084356 02/26/2016 14:Cgqckg.:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 2 of ladi000liao26 BOIES, SCHILLER & FLEXNER LLP S6. York Nal shire r California a New Jersey 4 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Forem
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
nt 1078-4 Filed 07/29/20 Page 2 of Dam 000liao26 BOIES, SCHILLER & FLEXNER LLP Ngsv York I Washinntore.
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
follows: I. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to pra
tial witnesses; and h. any person (1) who authored or received the particular Protected Material: (2) who has or had at any point in time access to the Protected Material outside of the context of this action: or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
Entities connected to both David Boies and the Protected Material

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONSigrid McCawley
PERSONthe Southern District
LOCATIONLaura Menninger
PERSON
New York
LOCATION
Foreman
PERSONBates
PERSONHaddon
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONChallenging Designations Of Protected Material
ORGANIZATIONthe non-party
ORGANIZATIONthe Receiving Party
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATION