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Case 1:20-cr-00330-PAE Document 307 Filed 06/25/21 Page2of21 meeting to provide the Government information on possible criminal conduct. The AUSA met with three attorneys who represented Giuffre on February 29, 2016. The AUSA’s notes from the meeting reflect that it focused primarily on Epstein. However, the notes also identify Maxwell as Epstein’s “head recruiter” of underage girls. The attorneys sent a few follow-up emails to the AUSA in the following weeks. The United States Attorney’s Office did not pursue a criminal investigation at that time. Maxwell claims based on a New York Daily News article published in October 2020 that a second meeting took place between federal prosecutors and a principal of BSF in the summer of 2016. The Government has represented to the Court that the AUSA who participated in the February 29, 2016 meeting did not participate in a second meeting with BSF attorneys and that the Government has “uncovered no evidence that such a meeting ever occurred.” Dkt. No. 204, at 92. However, for purposes of deciding this motion, the Court assumes that it occurred. About two weeks after the February 29, 2016 meeting, the judge presiding over the civil case entered a protective order that allowed the parties in that case to designate documents produced in discovery as confidential. See Dkt. No. 134-1. That order prohibited the parties from disclosing confidential documents to anyone other than people involved in the case. Although BSF initially proposed language that would allow disclosure of documents to law enforcement without a court order, the final version of the protective order included no such exception. The protective order did not require the parties to obtain the court’s approval to mark a document as confidential. It allowed the court to modify the order at any time for good cause after notice to the parties. It also allowed the parties to use any confidential information at trial, at which point that information would become public. It required the parties to return or destroy confidential records after the case ended. DOJ-OGR-00004786