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Case 1:20-cr-00330-PAE Document 191 Filed 03/30/21 Page 1 of 7

BSF BOIES SCHILLER FLEXNER

Sigrid S. McCawley
Telephone: (954) 377-4223
Email: smccawley@bsfllp.com

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 Ex 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 criminal sexual activity from 1994 to 1997. The facts underlying those charges involve three minor victims: Minor Victim-1, Minor Victim-2, and Minor Victim-3. The Government has also charged the Defendant with two counts of perjury for lying under oath during a civil deposition in a defamation action brought by Virginia Giuffre when asked if she was aware of Jeffrey Epstein’s sex trafficking scheme and whether she had ever given Minor Victim-2 a massage. BSF represents Minor Victim-2 (Annie Farmer) and Virginia Giuffre, but does not represent and has never represented Minor Victim-1 or Minor Victim-3.

Defendant has made clear since the time of her arrest that she seeks to impugn the credibility of her accusers by constructing a false narrative that BSF’s cooperation with the

BOIES SCHILLER FLEXNER LLP
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