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understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding `rea
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding `rea
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
understanding by a questioner and answerer," it is not fundamentally ambiguous. Id. at 375 (internal quotation marks omitted); see United States v. Jenkins, 727 F. App'x 732, 735 (2d Cir. 2018) ("An individual of ordinary intelligence would not think that a question asking for information regarding 'rea
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
Entities connected to both Jenkins and the "Government's

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Julie K. Brown
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Michael Jackson
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