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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
62 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329 (S.D.N.Y. 1998) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Joseph berg, 459 F.3d 350 (2d
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
except in the most extraordinary circumstances." Forde, 740 F.Supp.2d at 412 (citing Gaudin, 515 U.S. at 522-23). As the Supreme Court explained in Johnson v. United States, 520 U.S. 461 (1997), "there is no doubt that materiality is an element of perjury under § 1623," and its precedent "therefore dict
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
. 2013) 98 Int'l Equity Invs., Inc. v. Opportunity Equity Partners Ltd., No. 05 Civ. 2745 (JGK) (RLE), 2010 WL 779314 (S.D.N.Y. Mar. 2, 2010) 79 Johnson v. United States, 520 U.S. 461 (1997) 135 vi EFTA00095073 Kungys v. United States, 485 U.S. 759 (1988) Landgraf v. US! Film Products, 148 5
Entities connected to both Boies Schiller and Scarlett Johansson

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSONSouthern District
LOCATION
Bill Clinton
PERSON