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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 93 of 239 from that meeting. On or about December 6, 2018, AUSA-1 provided the prosecutors with her notes from the February 2016 meeting (which are attached as Exhibit 5) and documents the attorneys provided.*? Se The USAO-SDNY’s Subpoenas and Ex Parte Applications for Materials Shortly after opening the investigation in late November 2018, the Government identified possible victims and their counsel through public filings or media reports, which included Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). The USAO-SDNY first contacted Boies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to Boies Schiller that it intended to make document requests. Boies Schiller generally advised the Government that a protective order would govern some of the materials. (/d. at 3). In or about February 2019, approximately two months after the USAO-SDNY opened its investigation (and almost three years after the February 29, 2016 meeting described above), the USAO-SDNY issued two criminal grand jury subpoenas to Boies Schiller. One of the subpoenas requested non-privileged documents relating to Giuffre v. Maxwell, 15 Civ. 7433 (RWS); the other 3? The Government has reviewed the file that AUSA-1 provided to the prosecution team on or about December 6, 2018 and understands, based on a review of that file, that at the February 2016 meeting, AUSA-1 received copies of Epstein’s black book, flight records, and Palm Beach Police Department reports. Although AUSA-1 does not now recall the attorneys providing her with any documents at the meeting (Ex. 4 at 2), an email she sent to the prosecution team on December 6, 2018 refers to these documents as materials that the attorneys provided at the meeting. The Government notes that as of March 7, 2016, one week after AUSA-1’s February 29, 2016 meeting with the attorneys when she received these documents, Maxwell had only produced two emails in response to Giuffre’s discovery requests. (See 15 Civ. 7433 (LAP), Dkt. No. 43 at 1-2). None of the documents apparently provided to AUSA-1 during the February 2016 meeting was an email. Accordingly, the Government has no reason to believe that Giuffre’s counsel provided AUSA-1 with any discovery materials from the Giuffre v. Maxwell civil case. AUSA-1 also does not believe she ever received any such discovery materials. (Ex. 4 at 6). 66 DOJ-OGR-00003027