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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
1995) 77 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 248 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 144 United States v. McCourty, 562 F.3d 458 (2d Cir. 2009) 260 xvii EFTA00099958 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 257 United States v. Medina,
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
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCourty, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successivepunishments for the same off
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
1995) 53 United States v. Mason, 479 F. App'x 397 (2d Cir. 2012) 163 United States v. Mast, 735 F.2d 745 (2d Cir. 1984) 100 United States v. McCourty, 562 F.3d 458 (2d Cir. 2009) 170 United States v. McDarrah, 351 F. App'x 558 (2d Cir. 2009) 168 United States v. Medina, 13 Cr. 272 (PGG), 201
Entities connected to both Boies Schiller and McCourty

David Boies
PERSON
Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONMartindell
PERSON
Julie K. Brown
PERSON
United States
LOCATIONSweet
PERSONthe Southern District
LOCATIONColleen McMahon
PERSONChemical Bank
ORGANIZATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Supreme Court
ORGANIZATION
Schiller
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Eric Schmidt
PERSON
Colorado
LOCATION