📧 Communication

This document is a legal memorandum filed by Ghislaine Maxwell's defense team on January 25, 2021, seeking to suppress evidence obtained via subpoena from the law firm Boies Schiller Flexner. The defense argues that the government made false representations to Judge McMahon to bypass a civil protective order and obtain confidential deposition transcripts, alleging collusion between the civil plaintiff's lawyers (Boies Schiller) and federal prosecutors. The document details the history of the civil defamation case, specific deposition questions regarding sexual acts and Epstein, and the procedural history of the protective order modification.