183.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 7
Text status: Searchable text available
OCR confidence: 0.9438461485172601
Extracted text

Case 1:20-cr-00330-PAE Document183 _ Filed 03/26/21 Pagelof7 | BOIES SCHILLER is LEXNER             Sigrid S. McCawley Telephone: (954) 377-4223 Email: [email protected]   March 22, 2021 VIA EMAIL (FILED UNDER SEAL   The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Rule 17 Subpoena to Boies Schiller Flexner LLP Dear Judge Nathan: I write on behalf of Boies Schiller Flexner LLP (“BSF”) with respect to Defendant Ghislaine Maxwell’s motion for an order authorizing a subpoena on BSF pursuant to Rule 17(c)(3) of the Federal Rules of Criminal Procedure (the “Subpoena”) and the Court’s March 12, 2021, Sealed and x Parte Order requiring BSF to file a letter indicating (1) whether service on BSF can be deemed adequate notice on victims whose personal or confidential information the Subpoena is aimed at obtaining and (2) whether the victims object to or seek modification of the Subpoena. First, BSF does not object to service on BSF constituting adequate notice on any victims it represents. The Order and Subpoena, however, do not indicate which victims are to be provided with notice. The Order states that the Defendant identified five individuals who require notice, but the Subpoena appears to seek personal and confidential information about all of the Epstein victims that BSF represents, which is more than five individuals. Thus, in an abundance of caution, BSF will notify each of the Epstein victims it represents, unless otherwise directed by the court. Second, BSF, both on its own behalf and behalf of the women that it represents, objects to the Subpoena in its entirety for the following reasons. BACKGROUND The Government in this case has charged the Defendant with enticing (and conspiracy to entice) minors to travel to engage in illegal sex acts and transportation of (and conspiracy to transport) minors with intent to engage in crimi…
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