311-04.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 27
Text status: Searchable text available
OCR confidence: 0.9314396649736854

Extracted text

Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page1of27 EXHIBIT G DOJ-OGR-00004924

Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 2of27 To Be Filed Under Seal UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ( O PY IN RE GRAND JURY SUBPOENA * 19 Mise. 149 (CM) SEALED MEMORANDUM DECISION AND ORDER GRANTING THE GOVERNMENT’S APPLICATION TO MODIFY THE PROTECTIVE ORDER McMahon, C.J.: The Government has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. Robert W. Sweet in a civil defamation action, Giuffre v, Maxwell, No. 15-cv-7433 (S.D.N.Y.) (“the Giuffre Action”), in order to permit the law firm of Boies Schiller Flexner LLP (“Boies Schiller”) to comply with a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, Virginia L. Giuffre commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and J effrey Epstein (“Epstein”). (15-cv- 7433, Dkt. No. 1.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlement appeal, which is described below. On March 3, 2016, Maxwell moved before the assigned judge, the Hon. Robert W. Sweet, for entry of a protective order for materials produced in discovery. Maxwell cited SDNY_GM_00000875 DOJ-OGR-00004925

Case 1:20-cr-00330-PAE Document 311-4 Filed 07/02/21 Page 3of27 To Be Filed Under Seal statutory and common law privacy concerns. (Dkt. No. 38 at 1.) Maxwell submitted a proposed form of order for Judge Sweet’s consideration. (Dkt. No. 39-1.) Giuffre represented that she “[did] not oppose the entrance [sic] of a Protective Order in this case, but [did] oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation[.]” (15-cv-7433, Dkt. No.…

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