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ars found grooming behavior to be a means to "persuade, induce, or entice" minors to engage in illegal sexual activity. See, e.g., United States v. Thompson, 896 F.3d 155, 173 (2d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition wou
d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorv
s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m
71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.
DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.
DNY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Del Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical 34 Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief J
d Cir. 2018) ("Our precedent, however, supports applying a broad definition of enticement in this context: that definition would reasonably include Thompson's grooming of the minor victims to act as he desired with regard to many matters over the months before he made the video."); United States v. Dorve
ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub
71) 207, 211, 217 United States v. Tanu, 589 F.2d 82 (2d Cir. 1978) 79 United States v. Thai, 29 F.3d 785 (2d Cir. 1994) 252 United States v. Thompson, 13 Cr. 378 (AJN), 2013 WL 6246489 (S.D.N.Y. Dec. 3, 2013) 281, 284 United States v. Thompson, 896 F.3d 155 (2d Cir. 2018) 236 United States v.
NY and Boies Schiller] prior to the issuance of the subpoena on the subject of your investigation." (Def. Mot. 3, Ex. E at 2 (emphasis added)).34 In Chemical Tellingly, Maxwell omits the italicized portion of this question from her motion, thereby stripping important context from the nature of Chief Judg
Entities connected to both Thompson and Chemical

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Donald Trump
PERSONLeon Black
PERSON
Joe Biden
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON
George Mitchell
PERSON
Michael Jackson
PERSON
Stephen Hawking
PERSON
Marc Rich
PERSON
Colorado
LOCATIONCollins
PERSON