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United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329
r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
Jenkins, 727 F. App'x 732 (2d Cir. 2018) 130 xiv EFTA00095081 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 110 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 159, 176 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 28 United States v. Johnson, 21 F. Supp. 2d 329
bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n
District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
Entities connected to both Jimenez and Schiller

Jeffrey Epstein
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David Boies
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Ghislaine Maxwell
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Julie K. Brown
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United States
LOCATION
Scarlett Johansson
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Prince Andrew
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Virginia Giuffre
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Bradley Edwards
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Stephen Hawking
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George W. Bush
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ORGANIZATIONthe Southern District
LOCATIONJane Doe
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Colorado
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Eric Schmidt
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Michael Jackson
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Bill Richardson
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Donald Trump
PERSONMaria Farmer
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