DOJ-OGR-00003025.pdf

Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 91 of 239 Ex. 7), but AUSA-1 does not recall the details of that conversation (see Ex. 4 at 4), nor is the Government aware of any notes or other records documenting the substance of the call. The Government has not identified any records that suggest AUSA-1 ever communicated via email with Pottinger, Edwards, Skinner, or any other attorney at Boies Schiller regarding this matter after May 3, 2016. The USAO-SDNY did not open an investigation into Epstein or Maxwell in 2016. (Id. at 4). 3. The April and July 2016 Depositions of Maxwell On March 2, 2016, Maxwell moved for entry of a protective order for materials produced in discovery and submitted a proposed order for the consideration of the Honorable Robert W. Sweet, the United States District Judge who was then overseeing the Giuffre v. Maxwell civil litigation. (See 15 Civ. 7433 (LAP), Dkt. Nos. 38 & 39-1). On or about March 4, 2016, Boies Schiller represented that Giuffre did not oppose the entry of a protective order, but opposed the form proposed by Maxwell out of concern that it was overly broad and could lead to over-designation of material as confidential. (See 15 Civ. 7433 (LAP), Dkt. No. 40 at 2). Boies Schiller submitted a redline of Maxwell's proposed protective order, deleting some provisions and adding language that confidential material could be disclosed to law enforcement. (Def. Mot. 3, Ex. B). On March 18, 2016, Judge Sweet entered a protective order governing the discovery and dissemination of confidential information after the parties agreed to the form of the order originally proposed by Maxwell. (See 15 Civ. 7433 (LAP), Dkt. No. 62; see also Def. Mot. 3, Ex. G at 2-3). 64 DOJ-OGR-00003025