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Case 1:20-cr-00330-PAE Document 204 _ Filed 04/16/21 Page 116 of 239 court modified the protective order and issued a 26-page decision. The Government acted in reasonable reliance on the district court’s decision. The defendant argues that the Government misled the Court when it “claimed not to know what was in Boies Schiller’s file and that Boies Schiller had no role in instigating the investigation of Maxwell.” (Def. Mot. 11 at 1). The defendant’s claims are both factually inaccurate and meritless. First, the Government did not mislead Chief Judge McMahon about its contacts with Boies Schiller. As an initial matter, Maxwell’s argument is premised solely on her use of selective snippets from a lone Daily News Article that is premised, in meaningful part, on anonymous sources and hearsay. As the factual background set forth above—which is corroborated by notes and correspondence produced alongside this brief—makes clear, David Boies and Boies Schiller played no role in initiating, let alone “fomenting” the Government’s investigation. That investigation was opened more than two and a half years after the last known contact between any lawyer associated with any civil counsel for Giuffre and, in any event, was initially focused on Epstein, not this defendant. As detailed above, the USAO-SDNY opened the instant investigation in late November 2018 shortly after the Miami Herald published a series of articles about Epstein. AUSA-1 was not involved in that decision, which in any event had nothing to do with a meeting that had taken place nearly three years prior.*? (Ex. 4 at 6). °° Maxwell repeatedly claims that Boies Schiller urged AUSA-1 to open an investigation of Epstein and Maxwell, (Def. Mot. 3 at 8), but that allegation, which is supported by nothing aside from the above-referenced media report, is incorrect. While AUSA-1 did meet with the three attorneys in February 2016, she understood the attorneys to be focused on Epstein, and not on Epstein and Maxwell as a “duo.” (Ex. 4 at 1, 4). The presentation to AUSA-1 focused on urging an investigation into Epstein with only passing references to Maxwell. Simply put, the pitch was to investigate Epstein, not Maxwell. 89 DOJ-OGR-00003050