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Case 1:20-cr-00330-PAE Document204 _ Filed 04/16/21 Page 119 of 239 Second, the Government did not misrepresent the extent of its knowledge of the contents of Boies Schiller’s files. As the Government correctly represented to the court, the Government had “either little or no additional information than the Court does in terms of what materials there are [and] who was deposed.” (Def. Mot. 3, Ex. D at 17). In support of her argument, Maxwell cites again to the Daily News Article, which reports that “after Maxwell’s two depositions, David Boies himself apparently approached the government in the summer of 2016, asking ‘if the Southern District would consider charging Maxwell with perjury’” (Def. Mot. 3 at 8). But the Government has uncovered no evidence that such a meeting ever occurred. AUSA-1 does not recall ever speaking with or meeting David Boies in her life. (Ex. 4 at 4). Moreover, AUSA-1 does not recall being asked if the USAO-SDNY would consider charging Maxwell with perjury (id. at 5), and while notes of the February 2016 meeting refer to the existence of depositions generally, there can be no question Chief Judge McMahon appreciated the Government’s general understanding that such transcripts would be part of the civil litigation file. (Def. Mot. 3, Ex. G at 21). Simply put, there is no evidence that the Government had any significant knowledge of the contents of Boies Schiller’s files, or that the Government’s representations to Chief Judge McMahon were incorrect. In sum, Maxwell has failed to put forth any evidence that the Government misled Chief Judge McMahon, and as such, the good faith exception applies. To the contrary, the record before the Court demonstrates that the Government directly responded to Chief Judge McMahon’s question and accurately described the contacts between Boies Schiller and the USAO-SDNY in connection with the investigation, the Government’s lack of knowledge of the contents of that file, and the fact that no protected materials had been produced in violation of the protective order. Upon receiving a court order issued by a Chief United States District Judge who had carefully 92 DOJ-OGR-00003053