rief transcript of my conference with her earlier today. Also attached is the letter providing additional authority submitted this evening to Judge Netbum in connection with our similar application in her case. thanks, Assistant U.S. Attorney Southern District of New York EFTA00010708

Modify the Protective Order (19 Misc. 149 (CM)), 4/9/2019 EXHIBIT H: Sealed Order (19-MC-00179 (SN)), 4/16/2019 EXHIBIT I: Sealed Letter to Judge Netbum, 4/9/2019 iv EFTA00011456 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoen

n told that the government was given all the material as part of the Martindell-avoidance, ex pane processes in front of Judges Sweet, McMahon, and Netbum. The indictment with reference to sealed materials On July 2, 2020, one day after Ms. Maxwell filed her Reply concerning the unsealing of approxim

2021 14:34:50 +0000 This is a 2019 order that was recently unsealed. We made an application to modify a protective order in a civil case, and Judge Netbum denied the application. Ori inal Messa e From: (USANYS) aNIMME> Sent: Tuesda March 30 2021 10:21 AM To: Subject: Boies Schiller--Jeffrey Epst

From: " I" < IMIE> To: Min ale, ..S" Subject: draft letter to Netbum Date: Wed, 22 Jul 2020 17:52:20 +0000 Attachments: 2020-07-22, JEjetter to_Netbum_re_order on_unsealing.docx So I obviously had to do this pretty

ge Netburn rejected an identical request from the government in a different civil case, Jane Doe 43 v. Epstein, Case No. 17-cv-616 (JGK) (SN). Judge Netbum recognized the government's conduct for what it was: an attempt to deprive Maxwell of notice and an opportunity to be heard. Ex. H. Indeed, Judge N

modification of the Protective Order only "for good cause shown following notice to all parties and an opportunity to be heard"); Mot. Ex. H (Judge Netbum denying the government's ex parte request to modify the Jane Doe 43 Protective Order in part because the government was attempting to deprive Maxwe

Modify the Protective Order (19 Misc. 149 (CM)), 4/9/2019 EXHIBIT H: Sealed Order (19-MC-00179 (SN)), 4/16/2019 EXHIBIT I: Sealed Letter to Judge Netbum, 4/9/2019 iv EFTA00029820 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoen

From: ' )" To: ' )" Subject: RE: draft letter to Netbum Date: Wed, 22 Jul 2020 18:19:09 +0000 Attachments: 2020-07-22 JE letter to Netburn re order on unsealing.moe.docx Here are some proposed edits. Th

v_0616.pdf Yes, and sorry for the delay -- attached. Ori inal Messa e From: Sent: Sunda A r i•il > To: Subject: Epstein Can you send me Judge Netbum's opinion? Sent from my iPhone EFTA00031603