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LC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 20
Page: EFTA00028931 →District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut
Page: EFTA00028934 →dmits the following facts are true: • On February 29, 2016, AUSA M, the Human Trafficking Coordinator and Project Safe Childhood Coordinator for the U.S. Attorney's Office for the Southern District of New York, Ex. J, p 1, met with Peter Skinner of Boies Schiller, Stan Pottinger, and Brad Edwards, who represented M,
Page: EFTA00028935 →C), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23
Page: EFTA00029102 →District of New York. Contrary to the government's portrayal of events, what happened here is that a prosecutor from the public corruption unit of the United States Attorney's Office, in an a parte proceeding, affirmatively misled Chief Judge McMahon to circumvent a Protective Order entered by one of her colleagues. The prosecut
Page: EFTA00029105 →] or anyone else." Id. 7 Two other aspects to the privilege log are notable: (a) In the litigation, Boies Schiller did not produce its emails with the U.S. Attorney's Office to Maxwell, despite the fact that they were directly responsive to a Request for Production of Documents Maxwell served just a couple of weeks afte
Page: EFTA00029109 →ficers have ordered that all filings regarding those matters, including the discovery materials referenced in the Defense Letter, remain sealed? As the U.S. Attorney's Office for the Southern District of New York has stated publicly, the investigation into the conduct of the defendant in this case and other possible co-co
Page: EFTA00017807 →g the relative lack of specific guidance in the context of an application to modify protective orders in criminal cases), see also United States v. Morales, 807 F.3d 717, 721 (5th Cir. 2015) ("[m]otions to modify protective orders in criminal cases appear to be infrequent"), decisions that do exist have
Page: EFTA00017808 →Entities connected to both Morales and U.S. Attorney's Office

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONDistrict Court for the Southern District of New York
ORGANIZATION
Donald Trump
PERSONJane Doe
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
Michael Cohen
PERSON
Alexander Acosta
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONSecond Circuit
ORGANIZATION
George W. Bush
PERSON
William Barr
PERSON
Joe Biden
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON