DOJ-OGR-00004145.pdf

Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 10 of 34 "ongoing criminal investigation" into Maxwell, and they withheld from discovery 57 separate documents, invoking the "law enforcement privilege." Ex. P.7 In late November 2018 and early December 2018—just two months before AUSA filed the ex parte request before Judge McMahon seeking modification of the civil Protective Order entered by Judge Sweet—AUSA shared with AUSA , as well as one other member of the trial team and the heads of the Public Corruption Unit, everything she learned from her contacts with Giuffre's attorneys. Ex. N. AUSA gave AUSA and his colleagues: (1) nine pages of detailed, hand-written notes from the February 29 meeting; (2) the emails she received from Giuffre's attorneys; and (3) all the documents provided to her by Giuffre's attorneys. Id. Some of what she gave AUSA included material Boies Schiller attorneys designated a short time later as "confidential" under Judge Sweet's Protective Order, including flight records and Palm Beach Police Department Records. AUSA took an active role in gathering these materials from AUSA . Copying AUSA , AUSA had emailed AUSA on December 5, 2018, to obtain all the records of the February 29 meeting with Giuffre's attorneys. Id. at 1. In that email, AUSA also asked AUSA whether, after February 29, she met "again with [Peter Skinner] or anyone else." Id. 7 Two other aspects to the privilege log are notable: (a) In the Giuffre litigation, Boies Schiller did not produce its emails with the U.S. Attorney's Office to Maxwell, despite the fact that they were directly responsive to a Request for Production of Documents Maxwell served just a couple of weeks after those emails were sent; and (b) Peter Skinner, the Boies Schiller attorney at the AUSA meeting who also sent emails to AUSA after the meeting, Ex. L, is not even listed on the privilege log, though the log purports to reflect all email communications about the "ongoing criminal investigation" that Boies Schiller had tried to initiate just a couple of weeks earlier. 5 DOJ-OGR-00004145