Epstein Project

EFTA00030902.pdf

Type
pdf
Source set
data-set-8

Original source

Extracted text

From: ' 
r H 
To: a 
Subject: RE: Letter regarding discovery attached. 
Date: Wed, 12 Aug 2020 15:59:18 +0000 
Attachments: 2020-08-12,_GMJetter to_defense_counsel_re_discovery.docx 
Inline-Images: image001.jpg 
Draft letter response attached. Let me know if you have any revisions before I send to the chiefs. 
From: 
Sent: Monday, August 10, 2020 2:02 PM 
To: 
Subject: RE: Letter regarding discovery attached. 
Thanks for sending, 
M
.
 
I
 
agree with this approach, though defer to 
if she's handling, and thanks in advance. On 
the last point: I do think we have a firm view that they should not be filing our discovery materials in civil cases. I don't 
care about the substance of these particular documents, but I think we agree that is an important aspect of the protective 
order to assert, both in this instance and in general, so this issue doesn't continue to crop up. 
From: 
Sent: Monday, August 10, 2020 11:37 AM 
To: 
) 
Cc: 
I `:
=> 
Subject: FW: Letter regarding discovery attached. 
I think 
is particularly swamped this week —can you please take the lead on whatever we're going to do with this 
(i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly 
precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they 
relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond. 
(And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in 
our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract 
the obviously false claims about government malfeasance. 
All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it 
matters hugely. If we could have resolved 
(et al) by now, none of this would be an issu…

Open in the interactive archive →