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The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with perjury." (Def. Mot
ited States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 23 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 62, 72 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 259 United States v. Ewell, 383 U.S. 116 (1966) 80 EFTA00099954 United States v. Falso, 544 F.3d 110 (2d Cir. 2
Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magi
r. 2006) ("A claim of multiplicity cannot succeed, however, `unless the charged offenses am the same in fact and in law."' (quoting United States v. Estrada, 320 F.3d 173, 180 (2d Cir. 2003)). Although the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, a
The defendant's motion is, at its core, premised on a false factual narrative. The defendant alleges, based on a New York Daily News article, that Boies Schiller and the Government colluded 60 EFTA00095152 starting in at least early 2016 with the "precise[] design[]" of having the defendant "charged with
ited States v. E!-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001) 19 United States v. Elsbery, 602 F.2d 1054 (2d Cir. 1979) 43, 49 United States v. Estrada, 320 F.3d 173 (2d Cir. 2003) 169 United States v. Ewell, 383 U.S. 116 (1966) 54 xii EFTA00095079 United States v. Falso, 544 F.3d 110 (2d C
Entities connected to both Boies Schiller and Estrada

David Boies
PERSON
Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONMartindell
PERSON
Julie K. Brown
PERSON
United States
LOCATIONthe Southern District
LOCATIONSweet
PERSONJane Doe
PERSONColleen McMahon
PERSON
Supreme Court
ORGANIZATION
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONChemical Bank
ORGANIZATION
Schiller
PERSON
Southern District of New York
ORGANIZATION
Eric Schmidt
PERSON
Colorado
LOCATION