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2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 253 United States v. Pirro, 212 F.3d 86 (2d Cir. 2000) 229 United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236 (S.D.N.Y. Apr. 10, 2018) passim United States v. Plaza-Andrades, 507 F. App'x 22 (2d Cir. 2013) 291 Unit
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
rwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236, at *10 (S.D.N.Y. Apr. 10, 2018); see also 114 EFTA00077746 Franks, 438 U.S. at 171 ("To mandate an eviden
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
rwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236, at *10 (S.D.N.Y. Apr. 10, 2018); see also 114 EFTA00039561 Franks, 438 U.S. at 171 ("To mandate an eviden
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
, 2018) passim United States v. Pipola, 83 F.3d 556 (2d Cir. 1996) 166 United States v. Pino, 212 F.3d 86 (2d Cir. 2000) 151 United States v. Pizarro, No. 17 Cr. 151 (MN), 2018 WL 1737236 (S.D.N.Y. Apr. 10, 2018) passim United States v. Plaza-Andrades, 507 F. App'x 22 (2d Cir. 2013) 199 Unite
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
rwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236, at *10 (S.D.N.Y. Apr. 10, 2018); see also Franks, 438 U.S. at 171 ("To mandate an evidentiary hearing, the c
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
rwise presumed truthful." Falso, 544 F.3d at 125. "[C]onclusory allegations cannot support a Franks challenge as a matter of law." United States v. Pizarro, No. 17 Cr. 151 (AJN), 2018 WL 1737236, at *10 (S.D.N.Y. Apr. 10, 2018); see also 114 EFTA00103139 Franks, 438 U.S. at 171 ("To mandate an eviden
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 Pizarro 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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Bradley Edwards
PERSONJane Doe
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Stephen Hawking
PERSONColleen McMahon
PERSONMartindell
PERSONLoretta A. Preska
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Virginia Giuffre
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United States
LOCATIONSweet
PERSONthe Southern District
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Prince Andrew
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Michael Jackson
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Eric Schmidt
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Southern District of New York
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