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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
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00075099 02/26/2016 14:clafig aBt24)/7213GelfArneracti
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
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00084362 02/26/2016 IA iciP§Ax1:15-cv-07433-LAP Docume
nt 1078-4 Filed 07/29/20 Page 2 of Dam 000liao26 BOIES, SCHILLER & FLEXNER LLP Ngsv York I Washinntore.
written notice of, and the basis for, such objections. The Parties will use their best efforts to resolve such objections among themselves. Should the Receiving Party, the Producing Party and, if different, the Designating Party be unable to resolve the EFTA00094800 02/26/2016 IA iciP§Ax1:15-cv-07433-LAP Docume
Entities connected to both David Boies and the Receiving Party

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