10
Shared Docs
9
Same-Page
10 / 11
Mentions
us Tests To Historically Black Colleges. McClatchy <https://www.mcclatchydc.corn/news/coronavirus/article245910155.html#cardLink=row2_card2> (9/22, Chambers, 19K) reports, "In an effort to prevent potential COVID-19 outbreaks in high-risk communities, the Trump administration said it has started shipping
luence Efforts To Support Trump. The New York Times <https://vvww.nytimes.com/2020/09/22/us/politics/cia-russian-election-interference.html> (9/22, Barnes, Sanger, 18.6IM) reports Russian President Vladimir Putin is "most likely continuing to approve and direct interference operations aimed at raising
a tradition." However, McClatchy <https://www.mcclatchydc.corn/news/politics- govemment/election/article247039667.htmlticardLink=row2_card2> (11/7, Chambers, Wilner, 19K) reports sources "close to Trump" had "privately...acknowledged it was over, with one adviser telling McClatchy that only a 'handful'
/national/record-breaking-wave-of-coronavirus-cases- continues-to-sweep-the-nation/2020/11/08/4d2821e4-21ee-Ileb-a688-5298ad5d580a_story.html> (11/8, Barnes, 14.2M) says the "record-breaking wave of coronavirus cases" have "unsettled public health officials and politicians warned of a holiday season fil
soon to say that he will also invite his successor to the White House to meet before inauguration, which is a tradition." However, McClatchy (11/7, Chambers, Wilner, 19K) reports sources "close to Trump" had "privately...acknowledged it was over, with one adviser telling McClatchy that only a `handful' o
try is heading into a cold winter when infections are only expected to spread faster as people spend more time indoors." The Washington Post (11/8, Barnes, 14.2M) says the "record-breaking wave of coronavirus cases" have "unsettled public health officials and politicians warned of a holiday season fil
, adhere to health and safety guidelines, and vote. Administration Sending Rapid Coronavirus Tests To Historically Black Colleges. McClatchy (9/22, Chambers, 19K) reports, "In an effort to prevent potential COVID-19 outbreaks in high-risk communities, the Trump administration said it has started shipping
tour in Iraq, according to the USMC." CIA Finds Putin Most Likely Directing Election Influence Efforts To Support Trump. The New York Times (9/22, Barnes, Sanger, 18.61M) reports Russian President Vladimir Putin is "most likely continuing to approve and direct interference operations aimed at raising
tter known to some as the "Preppy Killer," was released after spending 15 years in prison for drug and assault charges, according to state records. Chambers spent a similar amount of time in prison after pleading guilty to strangling Jennifer Levin in New York City's Central Park during the summer of 198
lvement is mentioned in this context. U.S. Hunts Chinese Malware That Could Disrupt American Military Operations The New York Times (07/29, Sanger, Barnes) and CNN (07/29, lyer) reported that the Biden administration, along with U.S. military and intelligence officials, are concerned about malicious co
tter known to some as the "Preppy Killer;' was released after spending 15 years in prison for drug and assault charges, according to state records. Chambers spent a similar amount of time in prison after pleading guilty to strangling Jennifer Levin in New York City's Central Park during the summer of 198
lvement is mentioned in this context. U.S. Hunts Chinese Malware That Could Disrupt American Military Operations The New York Times (07/29, Sanger, Barnes) and CNN (07/29, lyer) reported that the Biden administration, along with U.S. military and intelligence officials, are concerned about malicious c
e previously used to obtain subpoenas in this case. As Defendants noted in their opposition papers, Defendants previously acted at the direction of Chambers to have subpoenas signed by the Clerk of Court. (Dcfs.' Glenwood Opp'n at 20.) In the future, however, the parties shall provide subpoena requests t
such requests' because the relaxed Tucker standard is not prevailing law of the Circuit.") (quoting Pena, 2016 WL 8735699, at *1); United States v. Barnes, 2008 WL 9359654, at '3 (S.D.N.Y. April 2, 2008) (Robinson, J.) ("Though the Tucker Court found this relaxed standard appropriate, it is not the pr
lth and safety guidelines, and vote. Administration Sending Rapid Coronavirus Tests To Historically Black Colleges. EFTA01658646 McClatchy (9/22, Chambers, 19K) reports, "In an effort to prevent potential COVID-19 outbreaks in high-risk communities, the Trump administration said it has started shipping
tour in Iraq, according to the USMC." CIA Finds Putin Most Likely Directing Election Influence Efforts To Support Trump. The New York Times (9/22, Barnes, Sanger, 18.61M) reports Russian President Vladimir Putin is "most likely continuing to approve and direct interference operations aimed at raising
soon to say that he will also invite his successor to the White House to meet before inauguration, which is a tradition." However, McClatchy (11/7, Chambers, Wilner, 19K) reports sources "close to Trump" had "privately...acknowledged it was over, with one adviser telling McClatchy that only a 'handful' o
try is heading into a cold winter when infections are only expected to spread faster as people spend more time indoors." The Washington Post (11/8, Barnes, 14.2M) says the "record-breaking wave of coronavirus cases" have "unsettled public health officials and politicians warned of a holiday season fil
ates v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700), abrogated on other grounds as recognized by United States v. Chambers, 751 F. App'x 44, 46 & n.1 (2d Cir. 2018) (summary order). It is not sufficient for a party to show only that the subpoenaed documents "are potenti
Page: EFTA00015866 →ed as 'a discovery device,' but instead should be used only as 'a mechanism for obtaining specific admissible evidence.'" (quoting United States v. Barnes, No. 04 Cr. 186 (SCR), 2008 WL 9359654, at *4 (S.D.N.Y. Apr. 2, 2008)). "Conclusory statements," like the defendant's here, are "insufficient to sat
Page: EFTA00015869 →pecify the information contained or believed to be contained in the documents sought rather than merely hop[e] that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 50868
Page: EFTA00015870 →Entities connected to both Chambers and Barneys New York

Jeffrey Epstein
PERSON
Scarlett Johansson
PERSON
Kenneth Marra
PERSON
United States
LOCATIONJane Doe
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Michael Jackson
PERSON
Prince Charles
PERSONEmmy Taylor
PERSON
Bloomberg L.P.
ORGANIZATION
Stephen Hawking
PERSON