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Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page45 of 92 8/13/2021) (See ORDER set forth) (ap) (Entered: 08/13/2021) ORDER as to Ghislaine Maxwell: On March 19, 2021, Defendant Ghislaine Maxwell submitted a sealed and ex parte motion for an order authorizing four subpoenas pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Procedure. By sealed order dated March 22, 2021, the Court provided an opportunity for recipients of the subpoenas to respond to the requests by March 30, 2021, but it received no responses. In an Opinion and Order temporarily filed under seal, the Court DENIES Maxwell's motion without prejudice. It does so after concluding that none of the proposed subpoenas conform to the factors first set out in United States v. Nixon, 418 U.S. 683, 69870 (1974). The Court will send the temporarily sealed Opinion and Order to defense counsel. By August 18, 2021, Maxwell is ORDERED to inform the Court whether she seeks sealing or limited redactions of the Court's opinion and of her original motion papers, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). In addition, by that date Maxwell shall inform the Court whether she seeks full sealing or redactions of the original motion, again justifying any such request by reference to the Lugosch test. (Signed by Judge Alison J. Nathan on 8/13/2021) (ap) (Entered: 08/13/2021) OPINION & ORDER as to Ghislaine Maxwell. Maxwell's motion is, at this time, DENIED without prejudice. She may renew any Rule 17(c) applications upon a proper showing that each of the requested materials satisfies the Nixon test, as described above and in the Court's April 27, 2021 and June 2, 2021 Orders. The Court will file this Opinion & Order under temporary seal to allow consideration of any sealing or redaction requests. (Signed by Judge Alison J. Nathan on 8/13/2021) (See ORDER set forth) (ap) (Entered: 09/03/2021) LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim dated 08/18/2021 re: Disruption of MDC attorney-client video teleconferences (Sternheim, Bobbi) (Entered: 08/18/2021) LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated August 18, 2021 re: Identification of co-conspirators Document filed by USA. (Rohrbach, Andrew) (Entered: 08/18/2021) ENDORSED LETTER as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C. Sternheim, dated 8/18/2021, re: Counsel writes: I write to update the Court regarding MDC ongoing interference with attorney—client communication between Ghislaine Maxwell and her counsel. ENDORSEMENT: The Government is hereby ORDERED to confer with BOP and MDC Legal and file a response to Defendant's letter on or before August 23, 2021. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/19/2021) (nl) (Entered: 08/19/2021) 08/19/2021 MEMO ENDORSEMENT as to Ghislaine Maxwell on 320 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated August 18, 2021 re: Identification of co-conspirators. ENDORSEMENT: The parties are hereby ORDERED to meet and confer in an effort to reach an agreement on the disclosure issues raised in this letter. If the parties reach an agreement, they shall inform the Court by August 26, 2021. If the parties do not reach agreement, the Defendant may file a response to the arguments made here by the Government on or before August 30, 2021. Any response letter shall confirm that the meet and confer occurred. SO ORDERED. (Signed by Judge Alison J. Nathan on 8/19/2021) (Inl) (Entered: 08/13/2021 les) _— joo 08/13/2021 (ee) (we aS 08/18/2021 les) _— KO 08/18/2021 lee) io 08/19/2021 Se) a 08/19/2021) 08/19/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated August 19, 2021 re: Redactions to Motion for 17(c) Subpoenas. (Everdell, Christian) (Entered: 08/19/2021) 08/20/2021 LETTER MOTION addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated August 20, 2021 re: Limited unsealing . Document filed by USA as to Ghislaine Maxwell. (Rohrbach, Andrew) (Entered: 08/20/2021) DOJ-OGR- 00020531