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Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page26 of 92

subpoena as required by Rule 17(c)(3). On March 19, 2021, the Court received a letter
from the law firm indicating that it can provide notice to alleged victims whose
personal or confidential information may be elicited by the subpoena. The law firm
shall provide notice to any such alleged victims it represents. In that letter, the law firm
also interposed substantial objections on behalf of the law firm and the alleged victims
it represents. Those objections are functionally the equivalent of a motion to quash,
even though the subpoena has not yet issued. So that the Court can receive adversarial
briefing on the proposed subpoena comparable to a motion to quash, the law firm shall
enter an appearance and file its objections on the public docket. See United States v.
Ray, No. 20-CR-110 (LJL), 2020 WL 6939677, at *10 (S.D.N.Y. Nov. 25, 2020)
("[I]f the Court determines that the subpoena calls for personal or confidential
information about a victim, it requires the requesting party have given notice to the
victim before it permits the service of the subpoena. If the victim objects, the Court
will then determine whether to modify or quash the subpoena, including on grounds
that Nixon was not satisfied."). In advance of noticing an appearance and filing, the
law firm shall meet and confer with defense counsel to see if any issues can be
narrowed before formal briefing. Moreover, prior to filing, the law firm shall confer
with defense counsel as to any proposed, necessary, and tailored redactions to the
objections. The law firm's objections with any proposed redactions shall be filed on or
before March 26, 2021. Any redactions must be justified consistent with Lugosch v.
Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Within one week of the filing
of objections, defense counsel may respond to the subpoena objections. The law firm
may reply within three days of the Defendant's response.(See Citation 1 on this Order).
Counsel shall confer regarding any proposed redactions for all briefing. SO
ORDERED. (Signed by Judge Alison J. Nathan on 3/24/2021)(bw) (Entered:
03/24/2021)

03/24/2021 | 173 | NOTICE OF APPEAL by Ghislaine Maxwell from 169 Order, Terminate Motions.
(tp) (Additional attachment(s) added on 4/1/2021: # 1 Appeal Fee) (tp). (Entered:
03/24/2021)

03/24/2021 | | Appeal Remark as to Ghislaine Maxwell re: 173 Notice of Appeal. $505.00 Appeal
Fee Due. (tp) (Entered: 03/24/2021)

03/24/2021 | | Transmission of Notice of Appeal and Certified Copy of Docket Sheet as to Ghislaine
Maxwell to US Court of Appeals re: 173 Notice of Appeal. (tp) (Entered: 03/24/2021)

03/24/2021 | | Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine Maxwell re: 173 Notice of Appeal were transmitted to
the U.S. Court of Appeals. (tp) (Entered: 03/24/2021)

03/24/2021 | 174 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)
03/24/2021 | 175 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)
03/24/2021 | 176 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)
03/24/2021 | 177 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)
03/24/2021 | 178 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)
03/24/2021 | 179 | SEALED DOCUMENT placed in vault. (dn) (Entered: 03/24/2021)

03/26/2021 | 180 | NOTICE of Appearance of David Boies for Boies Schiller Flexner LLP and the
Victims it Represents as to Ghislaine Maxwell (Boies, David) (Entered: 03/26/2021)

03/26/2021 | 181 | NOTICE of Appearance of Sigrid S. McCawley for Boies Schiller Flexner LLP and
the Victims it Represents as to Ghislaine Maxwell (McCawley, Sigrid) (Entered:
03/26/2021)

03/26/2021 | 182 | MOTION for Sigrid S. McCawley to Appear Pro Hac Vice . Filing fee $ 200.00,
receipt number ANYSDC-24312691. Motion and supporting papers to be reviewed
by Clerk's Office staff. Document filed by Boies Schiller Flexner LLP as to Ghislaine
Maxwell. (Attachments: # 1 Declaration of Sigrid S. McCawley, # 2 Florida
Certificate of Good Standing, # 3 District of Columbia Certificate of Good Standing, #
4 Text of Proposed Order)(McCawley, Sigrid) (Entered: 03/26/2021)

DOJ-OGR-00020512