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Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_ 00000905), namely that the Order itself may be provided to Boies Schiller & Flexner LLP, and, pursuant to separate permissions the Government has obtained in connection with its discovery obligations, that the entirety of the Unsealing
Page: EFTA00021902 →fidential" designation of the Unsealing Materials is appropriate because they pertain to an ongoing grand jury investigation and because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netburn have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the
Page: EFTA00021902 →ave ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the permission contained in Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_ 00000905), namely that the Order itself may be provided to Boies Schiller & Flex
Page: EFTA00021902 →s to those sealing orders are the production of Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the entirety of the Unsealing Materials to Ms. Maxwell as discovery in the above-referenced criminal case. The Unsealing Materia
Page: EFTA00030904 →l matter. If the former, the Government maintains that the "Confidential" designation of the Unsealing Materials is appropriate because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the
Page: EFTA00030904 →h Netbum have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the production of Chief Judge McMahon's April 9, 2019 Order (Bates Nos. SDNY_GM_00000904 through SDNY_GM_00000905) to Boies Schiller & Flexner LLP, and production of the entirety of the
Page: EFTA00030904 →on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00077607 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Gover
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00039422 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
on to the public, as part of an ongoing campaign to vilify Ms. Maxwell." (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP ("Boles Schiller") to obtain materials from the civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government o
ces the Instant Investigation in 2018 65 5. The USAO-SDNY's Subpoenas and Ex Pane Applications for Materials 66 6. Proceedings before Chief Judge McMahon 68 a. March 26, 2019 Hearing 68 b. April 9, 2019 Hearing 70 EFTA00103000 c. Chief Judge McMahon's Memorandum and Order 71 7. Magistrate Judge
Entities connected to both Boies Schiller & Flexner LLP and Colleen McMahon

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Julie K. Brown
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Bradley Edwards
PERSONMartindell
PERSON
New York
LOCATION
George W. Bush
PERSONJane Doe
PERSON
Colorado
LOCATIONSecond Circuit
ORGANIZATIONJeffrey Pagliuca
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON