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Casets2025-ON S302 AR NVAD GSH RENEALASD, PHUGCIUA/ BGIS2 | PAracERF of 8 App.-0133 INTRODUCTION Ms. Maxwell, through counsel, requests, pursuant to Rules 37( a) and 26(c) of the Federal Rules of Civil Procedure that the Court enter an order requiring Plaintiff to either disclose any purported ongoing criminal investigations and any alleged supporting documents or enter an order staying these proceedings pending the resolution of the purported “on-going criminal investigations [sic]”. In support of this motion, Ms. Maxwell states: Throughout the pendency of this case Plaintiff repeatedly has represented to the Court and Ms. Maxwell that she is privy to, and part of, some ongoing criminal investigation in which, per Plaintiff's innuendo, Ms. Maxwell is a person of interest. For example, Plaintiff purports to be withholding documents “relating to on-going [sic] criminal investigations by law enforcement relating to [Ms. Maxwell’s] conduct.” See Plaintiff's Response in Opposition to Defendant’s Motion to Compel (Doc. #78) at 3. Plaintiff claims to be withholding “documents that concern or relate to any currently ongoing investigation by any law enforcement agency under the public interest privilege and other applicable privileges.” Jd. at 4. According to Plaintiff, she “can immediately provide clear evidence to this Court of how [the purportedly ongoing] investigation would be impaired...” /d. at 11. Further, Plaintiffrefers to “the law enforcement inquiry that is currently underway,” id., representing to the Court that, in fact, there is an active investigation regarding Ms. Maxwell. Ms. Maxwell is not aware of any such investigation. Indeed, a review of the now more than a decade old police reports involving Mr. Epstein reflects that Ms. Maxwell was not a suspect in any of the activity which resulted in any prosecution of Mr. Epstein. Counsel for Ms. Maxwell have attempted to learn about any investigation by contacting Assistant United States Attorney A. Marie Villafana, the Government lawyer handling the VRA litigation that Plaintiff DOJ-OGR-00003797