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Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 14 of 23 At that time, however, the government did not act. Boies “was particularly frustrated by the failure to pursue a perjury charge [against Maxwell],” reported one person, who recalled him saying, “We have her dead to rights.”° Jd. All of this contradicts The government’s representations to i, who spccifical|y as ee Reassured by the government that i modified the Protective Order so that J could comply with the subpoena. Ex. F. PS fur ht es ES [2king this finding, BE cc licd on the Assistant U.S. Attorney’s misrepresentations, and she Ree (com the subpoena at issue in Chemical Bank. Said Ex. G, p 21. > Ms. Maxwell strenuously disagrees with Mr. Boies’ comments. We reference them here only to show their connection to the perjury counts that the government subsequently charged. 9 DOJ-OGR- 00002361