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Case 1:20-cr-00330-PAE Document 244 _ Filed 04/23/21 Page3of14 The Honorable Alison J. Nathan April 2, 2021 Page 3 fact, none of the requests contains the words “any” or “all” because they are specifically limited to communications between BSF and the USAO-SDNY about Ms. Maxwell and and communications between BSF and their co-counsel in the Giuffre v. Maxwell matter about those known meetings. BSF tries to cobble an “any or all” argument together by picking the word “any” from the definition section of the subpoena identifying the two entities, BSF and the USAO-SDNY, and attaching it to the word “all” from a separate paragraph defining “communication.” Of course, absent these definitions, BSF would be complaining that the subpoena was vague because it failed to define either the entities involved or what was meant by “communication.” Significantly, BSF already identified some of the communications between itself and the government. According to its so called “Plaintiff Virginia Giuffre’s Revised Supplemental Privilege Log Dated April 29, 2016,” BSF refused to produce as privileged “approx. 57” documents that it identified as “correspondence re the currently ongoing criminal investigation of the Defendant [Ms. Maxwell] and others.”! Entry 153 in the log identified “email and letter ' The privilege log was produced in response to an interrogatory, served by Ms. Maxwell’s counsel on BSF, as counsel for Virginia Roberts, which asked in relevant part that they “TiJdentify each Communication, including the transmission of any Document, that You or Your Attorneys have had with any local, state or federal law enforcement agent or agency, whether in the United States or any other country, whether in Your capacity as a purported victim, witness, or perpetrator of any criminal activity, and whether as a juvenile or as an adult, including without limitation: a. the date of any such Communication; b. the form of any such Communication, whether oral or written and if written, the format of any such Communication; c. the identities of all persons involved in the Communication, including the identity of the law enforcement agency with whom the agent is or was affiliated; d. the case number associated with any such Communication; e. the subject matter of any such Communication; f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed.” DOJ-OGR-00003974