DOJ-OGR-00019292.pdf

Case 20-3061, Document 17, 09/10/2020, 2928288, Page6 of 15 arguments made by Ms. Maxwell that material should remain sealed because of the potential for a criminal investigation. E.g., EXHIBIT C, p 2. For example, when Ms. Maxwell moved to stay discovery in Farmer v. Indyke, Case No. 19-cv-10475 (LGS-DCF) (S.D.N.Y.), due to the pending criminal investigation, Ms. Giuffre opposed the motion on the grounds that Ms. Maxwell could not show the existence or scope of any such criminal investigation, Maxwell has provided no information about the subject matter of the criminal investigation into Epstein's co-conspirators, the status of the investigation, or even disclosed whether she herself is a target of the Southern District's investigation. When Plaintiff's counsel asked Maxwell's counsel for information about the criminal investigation during their meet and confer, Maxwell's counsel refused to provide any details. Ex. C, p 2. 5 DOJ-OGR-00019292