DOJ-OGR-00004910.pdf

Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 17 of 23 xj3q1gra SEALED 1 but of course this is fine for you to disclose this information to the government based on the validly issued grand jury subpoena, I think for the same type of reasons that the Court is describing. 2 3 THE COURT: Okay. So let me see what other million questions that I have. 4 5 It's a general subpoena. Did you take them for all discovery materials? I mean, everything that's in Boies Schiller's files, other than privileged documents, which of course you don't exclude from your subpoena but presumably they will exclude from their production. But it's literally everything. So remember, I know very little about the Maxwell case, both because it wasn't my case and, to the shock of nearly everyone that I talk to, we're all too busy to worry about some litigation that's being handled by somebody else; and second, it seems to have been litigated entirely under seal so how could I have found out anything about it. Everything I know about this case I learned from reading about the Second Circuit argument. Literally, everything. 6 7 So what assurance do I have that so broad a grand jury subpoena -- given that I have these competing interests between the terms of the protective order and the government's interest in conducting an investigation, what assurance do I have that you need all that stuff, that that's all somehow going to be relevant to your investigation? That is a concern from me 8 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 SDNY_GM_00000868 DOJ-OGR-00004910