DOJ-OGR-00002361.pdf

Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 14 of 23 At that time, however, the government did not act. Boies “was particularly frustrated by the failure to pursue a perjury charge [against Maxwell],” reported one person, who recalled him saying, “We have her dead to rights.”5 Id. All of this contradicts The government’s representations to , who specifically . Reassured by the government that modified the Protective Order so that could comply with the subpoena. Ex. F. found that . In making this finding, relied on the Assistant U.S. Attorney’s misrepresentations, and she from the subpoena at issue in Chemical Bank. Said Ex. G, p 21. 5 Ms. Maxwell strenuously disagrees with Mr. Boies’ comments. We reference them here only to show their connection to the perjury counts that the government subsequently charged.