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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 92 of 239 The protective order, among other things, restricted the parties from disclosing discovery materials marked confidential to third parties, absent express permission from the Court. In connection with the defamation suit, Maxwell was deposed by Boies Schiller, counsel for Giuffre, on April 22, 2016 and July 22, 2016. On or about May 24, 2017, the parties entered into a settlement agreement and voluntarily dismissed the civil action. (See 15 Civ. 7433 (LAP), Dkt. No. 916). Boies Schiller has continued to represent Giuffre in post-settlement litigation. Giuffre v. Maxwell, No. 18-2868 (2d Cir.); Giuffre v. Maxwell, No. 20-2413 (2d Cir.). 4. The USAO-SDNY Commences the Instant Investigation in 2018 On or about November 29, 2018, the USAO-SDNY initiated its investigation into Epstein and possible co-conspirators, and formally opened the investigation by completing the requisite paperwork to open an investigation on or about November 30, 2018. The investigation was prompted by a series of articles published by the Miami Herald earlier that same week relating to Epstein, his conduct, and the circumstances of his prior conviction. See Julie K. Brown, “Even from Jail, Sex Abuser Manipulated the System. His Victims Were Kept in the Dark,” Miami Herald (Nov. 28, 2018).*!_AUSA-1 was not involved in the decision to open the investigation or in the investigation itself. (See Ex. 4 at 6). Indeed, AUSA-1 stopped serving as the Office’s Human Trafficking and Project Safe Childhood Coordinator as of April 2017. Shortly after initiating the investigation, the prosecutors involved in the investigation learned of the prior February 2016 meeting and requested copies of AUSA-1’s notes and records 31 Indeed, on July 8, 2019, at the press conference following the arrest of Epstein, Geoffrey S. Berman, then United States Attorney for the Southern District of New York, stated that while he was not “going to go into any aspects of how our investigation originated[,] I will say that we were assisted from some excellent investigative journalism.” 65 DOJ-OGR-00003026