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dle to getting any bill done." The President also said Senate Majority Leader McConnell "is in favor of expanding background checks." Reuters (8/13, Mason) reports Trump told reporters, I am convinced that Mitch wants to do something.' The New York Times (8/13, Stolberg, Edmondson, 18.61M) reports, "Wh
d charged with third-degree felony terroristic threat." Porter asked, "I'd like to know if he has any bomb-making ability." KTRK-TV Houston (8/13, Schiller, 431K) reports Fonseca "is facing a felony charge after police say he made a terroristic threat on Snapchat." KPRC-TV Houston (8/13, McCord, Arche
7 999 p) /2638638842 ärk 83 wf) ) Ast. Tash Courage nalasha.cour- [email protected].~ u Martins Peter Marzotto, Matteo Valondno 38 83 83183 ei (0 Mason, Christopher 330t 9th St Ne .NY 10021 001 675 0989(h) 001 517 6832 (h) Massimo Parisi IIIMR Modelt 1139 335 360 8950) 113902 58316 269(f)
011o hj Email: 1 6 3 823 Schiatti, Gianmarco a r p 71841712w(?) rig i 121 RI) Schiffer, Helen & Tim 784 Parx Ave NYC 646 226 4696 Hen+len P Schiller P 516 537 7744 2nd home Sebag Montefiroe Simon & Santa 838N831-1911 Seilern Christine 302/15c W12th St NYt h) 881 W) Sejoumet, Isabel de
3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 216 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2
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
(citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 5S Minor Victim-3 has been a she was invitedil when she was 18 years old. Regardless, the subsequent invita
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
(citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 5S Minor Victim-3 has been a she was invitedil when she was 18 years old. Regardless, the subsequent invita
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
3 WL 322768 (S.D.N.Y. Aug. 19, 1993) 144 United States v. Martinez, No. 94 Cr. (RPP), 1995 WL 10849 (S.D.N.Y. Jan. 12, 1995) 53 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 163 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 100 United States v. McCourty, 562 F.3d 458 (2d Cir. 2
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
(citing Grunewald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). Accordingly, overt acts that may, on their own, be untimely can nevertheless serve as direct evidence of the
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
) (citing Grunwald v. United States, 353 U.S. 391, 396-97 (1957)); United States v. Rutkoske, 506 F.3d 170, 174-75 (2d Cir. 2007); United States v. Mason, 479 F. App'x 397, 398 (2d Cir. 2012). 58 egar ess, e su sequent mvitatton emonstrates t e grooming an sex acts in Lon on were part of conspiraci
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 Mason and Schiller

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