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Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 6 of 23 Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to I and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm’s clients. Giuffre v. Maxwell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two Maxwell depositions) with anyone else, including with the government and law enforcement. Faced with that Protective Order, the government issued a SEES. By proceeding ex parte, the government ensured that no one before the court would be able to contest the accuracy of its representations in support of its application. The government then took full advantage. i DOJ-OGR-00002353