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" Business Insider <https://www.businessinsider.corn/gennany-is-growing-target-for-china-and-russia-cannot-rely- on-trump-report-says-2020-7> (7/29, Payne, 3.67M) reports the report by the London-based defence think tank "comes as the White House formally announced that it will pull out thousands of tr
<https://www.washingtonpost.com/national/portland-federal-officers-withdraw/2020/07/29/6a9106ae-dlbe-1 lea- 9038-af089b63ac2l_stoty.html> (7/29, Al, Berman, Miroff, Lang, Fahrenthold, I4.2M) says "the specific timing of how this would play out remained unclear." On its editorial page, the Wall Street J
sion and cultural panic now underway." Politico Analysis: Congressional Security Spending Has "Surged" Since Capitol Riot. Politico (4/16, Ferris, Payne, 6.73M) reports "more than one third of the 17 GOP lawmakers who voted to impeach of convict" former President Donald Trump "used campaign funds to
, Holt, 4.83M) that Hole "was known to local police and FBI EFTA00135871 for a mental health condition." The Washington Pact (4/16, Molloy, Bella, Berman, Witte, 10.52M) reports that as Hole's shotgun was "seized and not returned, it was unclear how he had obtained the rifle used Thursday night." The
a new Cold War." In his writing, Kampfner "says the threats Germany faces from Russia are mostly linked to cybersecurity." Business Insider (7/29, Payne, 3.67M) reports the report by the London-based defence think tank "comes as the White House formally announced that it will pull out thousands of E
iolent clashes that have stained the city," the AP (7/29, Flaccus, Balsamo) notes "each side declared victory," while the Washington Post (7/29, Al, Berman, Miroff, Lang, Fahrenthold, 14.2M) says "the specific timing of how this would play out remained unclear." On its editorial page, the Wall Street J
ssion and cultural panic now underway." Politico Analysis: Congressional Security Spending Has "Surged" Since Capitol Riot. Politico (4/16, Ferris, Payne, 6.73M) reports "more than one third of the 17 GOP lawmakers who voted to impeach of convict" former President Donald Trump "used campaign funds to
ad story, 2:34, Holt, 4.83M) that Hole "was known to local police and FBI for a mental health condition." The Washington Post (4/16, Molloy, Bella, Berman, Witte, 10.52M) reports that as Hole's shotgun was "seized and not returned, it was unclear how he had obtained the rifle used Thursday night." The
a new Cold War." In his writing, Kampfner "says the threats Germany faces from Russia are mostly linked to cybersecurity." Business Insider (7/29, Payne, 3.67M) reports the report by the London-based defence think tank "comes as the White House formally announced that it will pull out thousands of t
iolent clashes that have stained the city," the AP (7/29, Flaccus, Balsamo) notes "each side declared victory," while the Washington Post (7/29, Al, Berman, Miroff, Lang, Fahrenthold, 14.2M) says "the specific timing of how this would play out remained unclear." On its editorial page, the Wall Street J
man, Rachel Kenneway, Deborah King, Angela King., Mercedes Kinsey, Charles (So Cnty) (Exec) (Appeals) (INTAKE) (Fel R) (So Cnty) (INTAKE) Payne, Both' (Gun Club) Penh, Nicoll* (So env) Penn, Candace (Eco Crimes) Philip, Eva (HOM) Phillips, Marci (Traf Hom) Pierce, Rita (CC P) Pine,
r, bestirsle Gallus, Sharon Bass, T. Hardee Beard, Gary Beaudetailtin,Kathieen Beckwith, Tim Belcher, Laura Belohlavek, Lanna Bennett, April Berman, Howard Bishop, Tammy Boons, Ted Bramhall, Terri Bridgeman, Shane Brooks, Sandra Brown, Asim Brown, Florence Brown. Robin Brown, Sophie Bro
MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00027307 --- PAGE BREAK --- Case 1:
Page: EFTA00027307 →1210 (2d Cir. 1983) 30, 33 iii EFTA00027310 --- PAGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 5 of 34 United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelull°, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United
Page: EFTA00027311 →MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Assistant United States Attorneys - Of Counsel - EFTA00031263 --- PAGE BREAK --- TABLE O
Page: EFTA00031263 →.D.N.Y. Aug. 17, 2018) 20, 22 United States v. Moon, 718 F.2d 1210 (2d Cir. 1983) 30, 33 iii EFTA00031266 --- PAGE BREAK --- United States v. Payne, 63 F.3d 1200 (2d Cir. 1995) United States v. Pelullo, 399 F.3d 197 (3d Cir. 2005) United States v. Perez, 940 F. Supp. 540 (S.D.N.Y. 1996) United
Page: EFTA00031267 →Entities connected to both Payne and Geoffrey S. Berman

Jeffrey Epstein
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATIONFBI
ORGANIZATIONSouthern District
LOCATION
Donald Trump
PERSON
New York
LOCATIONMartin Weinberg
PERSONLeon Black
PERSON
George W. Bush
PERSON
Stephen Hawking
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Harry Reid
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Reid Weingarten
PERSON