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d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00728026 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her
Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil-A. Inc. v. CFT Dev.. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. I
d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00207349 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her
Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil-A. Inc. v. CFT Dev.. LLC 652 F. Supp. 2d 1252 (M.D. Fla. 2009) 12 Cooper Industries. Inc. v. Leatherman Tool Group. I
witnesses to this action, as is standard practice by their office and others in this jurisdiction. See, e.g., Securities and Exchange Commission v. Carroll, 19 Civ. 7199 (AT), 2020 WL 1272287, at *1 (S.D.N.Y. Mar. 17, 2020); Securities and Exchange Commission v. Abraaj Investment Management Limited, 19
stment Management Limited, 19-CV-3244 (AJN), 2019 WL 6498282, at *1 (S.D.N.Y. Dec. 3, 2019); Nesbitt v. Benner, 18-CV-00699 (VLB), 2018 WL 5619716 (E.D.N.Y. Oct. 30, 2018) (staying Trafficking Victims Protection Act civil case during pendency of related state court prosecution). Ms. Maxwell simply seeks
FBI's Child Exploitation and Human Trafficking Task Force, federal officials say. According to the article, federal authorities began investigating Carroll after a Discord employee reported a suspected file of child sexual abuse material that was uploaded onto the messaging app's servers on Sept. 11. In
etly build extraordinarily large positions in just a few companies. A DOJ press release notes that this case was investigated by the U.S. Attorney's Office for the Southern District of New York and the FBI. The Wall Street Journal (11/20, Telesca), New York Times (11/20, Goldstein), Reuters (11/20, Cohen, Stempel), New York Post (11/20, Ba
Entities connected to both Carroll and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONJane Doe
PERSONJack Goldberger
PERSON
George W. Bush
PERSONSouthern District
LOCATION
Scarlett Johansson
PERSONLeon Black
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Michael Jackson
PERSON
Michael Cohen
PERSON