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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
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
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
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
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
ICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel -
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 →can refer you to the appropriate Assistant United States Attorney in our office's Civil Division, who will process your request. Very truly yours, AUDREY STRAUSS Acting United States Attorney By: / Assistant United States Attorneys Southern District of New York Tel: EFTA00021903
Page: EFTA00021903 →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 →can refer you to the appropriate Assistant United States Attorney in our office's Civil Division, who will process your request. Very truly yours, AUDREY STRAUSS Acting United States Attorney By: Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 EFTA00030905
Page: EFTA00030905 →Entities connected to both Boies Schiller & Flexner LLP and Audrey Strauss

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSONSouthern District
LOCATIONthe Southern District
LOCATION
Denver
LOCATIONLeon Black
PERSON
Alison J. Nathan
PERSON
United States
LOCATION
Colorado
LOCATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSONRubin
PERSON
Tony Blair
PERSONJeffrey Pagliuca
PERSONDistrict Court for the Southern District of New York
ORGANIZATIONFBI
ORGANIZATION