Epstein Secrets

Confidential Draft 11/16/10 EFTA_R1_00021292 EFTA01736173 • Marc Andreessen (Netscape, Andreessen Horowitz) • Steve Case (AOL, Revolution) • Eric Schmidt (Google) • Sheryl Sandberg (Facebook) • Marc Pincus (Zynga) • John Doerr (Kleiner Perkins) • Mike Moritz (Sequoia) • Danny Rimer (Index) • Ron

Horowitz) • Steve Case (AOL, Revolution) • Eric Schmidt (Google) • Sheryl Sandberg (Facebook) • Marc Pi

ozen & Obama Admin) • Robert Morgenthau (Wachtel Lipton) • Katherine Lapp (Harvard University) • Bruce Ratner (Forest City Ratner) • David Boies (Boies Schiller) • Stephen Berger (Odyssey Partners) • Chris Flowers (JC Flowers & Co.) • John Catsimatidis (Red Apple Group) • Bruce Gelb (Bristol Myers) • Rog

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation o

in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all c

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation o

in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all c

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation o

in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all c

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation o

in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all c

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation o

in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all c

), 2019 WL 267711 (D. Or. Jan. 17, 2019) 121 xxi EFTA00099962 United States v. Schalk-id-, 871 F.2d 300 (2d Cir. 1989) 182 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 153, 154 United States v. Schneider, 801 F.3d 186 (3d Cir. 2015) 51,52,54,57 United States v. Seabrook, No. 10 Cr

The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with perjury." (Def. Mot

mon notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82,91 (2d Cir. 1997) (internal quotation marks and citations omitted). "Such outrageous or conscience shocking behavior involves egregiou

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magi

fer, No. 17 Cr. 400 (HZ), 2019 WL 267711 (D. Or. Jan. 17, 2019) 86 United States v. Schafrick, 871 F.2d 300 (2d Cir. 1989) 121 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 105 United States v. Schneider, 801 F.3d 186 (3d Cir. 2015) 37, 38, 39, 40 United States v. Seabrook, 10 Cr. 87 (D

The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA00095152 starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with

18 IV. The Remedy for the Government's Misconduct 20 A. Pursuant to its Inherent Power, this Court Should Suppress the Evidence Obtained from Boies Schiller and Dismiss Counts Five and Six, which are the Fruits of that Evidence. 20 B. At a Minimum, this Court Should Order a Hearing at which Maxwell Ma

447 U.S. 727 (1980) 20 United States v. Pena, 961 F.2d 333 (2d Cir. 1992) 25 United States v. Russell, 411 U.S. 423 (1973) 21 United States v. Schmidt, 105 F.3d 82 (2d Cir. 1997) 23 Wang v. Reno, 81 F.3d 808 (9th Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities St

ew all of this and still denied that Boies Schiller had any role in fomenting the investigation and claimed that there had been no contacts between Boies Schiller and his office before November 2018, when he claimed the investigation first began. None of these statements by AUSA to Judge McMahon were true.