DOJ-OGR-00019406.jpg

Case 20-3061, Document 60, 09/24/2020, 2938278, Page7 of 58 Ms. Maxwell sat for two depositions during discovery in Giuffre v. Maxwell, the transcripts of which were both designated “confidential” under a court- ordered protective order. App. 154-59. The transcripts of both depositions were filed with the court during the course of the case and sealed by the court under the terms of the protective order. In turn, the civil protective order prohibited attorneys and parties from sharing confidential information, including Ms. Maxwell’s depositions, with any third party, except as necessary for the preparation and trial of the case. App. 155- 56. As originally proposed by Ms. Giuffre’s attorneys, the protective order would have allowed plaintiff to share confidential information with law enforcement. App. 125. Ms. Maxwell objected to this language, which was removed and never made part of a court order. App. 125 & n.4. The subpoena. So if the civil protective order did not allow plaintiff to share confidential information with law enforcement, and Ms. Maxwell did not provide the government with her deposition transcripts (which she didn’t), how did the government obtain them and bring a criminal indictment alleging that Ms. Maxwell committed perjury? DOJ-OGR-00019406