Epstein Secrets

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

ictim-3's experiences in the Indictment "may not be stricken" "regardless of how prejudicial the language is .. ." Scarpa, 913 F.2d at 1013 (quoting DePahna, 461 F. Supp. at 797). Finally, even if Minor Victim-3's experiences did not constitute direct evidence of the crimes charged—which they do—this s

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

ictim-3's experiences in the Indictment "may not be stricken" "regardless of how prejudicial the language is .. ." Scarpa, 913 F.2d at 1013 (quoting DePahna, 461 F. Supp. at 797). Finally, even if Minor Victim-3's experiences did not constitute direct evidence of the crimes charged—which they do—this s

ited number of emails from the attorneys (see Exs. 6 & 7).3° AUSA- I did not participate in a second meeting with those attorneys and has never met David Boies. (See Ex. 4 at 4). AUSA- I recalls being aware of depositions as a general matter, but she does not recall having knowledge of who had been deposed

ges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA000

17 Cr. 585 (WHP), 2018 WL 740727 (S.D.N.Y. Jan. 31, 2018) 114 United States v. Delacruz, 970 F. Supp. 2d 199 (S.D.N.Y. 2013) 53 United States v. DePahna, 461 F. Supp. 778 (S.D.N.Y. 1978) 159, 164 United States v. Dewar, 489 F. Supp. 2d 351 (S.D.N.Y. 2007) 112 United States v. Diaz, 176 F.3d 52

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' (

ant to the charge, then regardless of how prejudicial the language is, it may not be stricken." Id. (brackets in original) (quoting United States v. DePahna, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and o