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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
ed States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 124, 132 United States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 228, 229, 231 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 180, 190 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 170 EFTA00099963 United States v. Sweig, 441
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
amenable to multiple meanings, or that an answer "might generate a number of different interpretations." Lighte, 782 F.2d at 375; United States v. Strohm, 671 F.3d 1173, 1178 (10th Cir. 2011) ("Simply plumbing a question for post hoc ambiguity will not defeat a perjury conviction where the evidence de
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
States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 87, 93, 94 United States v. Stringer, 730 F.3d 120 (2d Cir. 2013) 151, 152, 153 United States v. Strohm, 671 F.3d 1173 (10th Cir. 2011) 120, 127 United States v. Swanson, 210 F.3d 788 (7th Cir. 2000) 115 United States v. Sweig, 441 F.2d 114 (2d C
Entities connected to both Boies Schiller and Strohm

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
United States
LOCATION
Donald Trump
PERSON
Virginia Giuffre
PERSON
Colorado
LOCATION
Supreme Court
ORGANIZATION
Chris Tucker
PERSON
Michael Jackson
PERSON
George Mitchell
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Bloomberg L.P.
ORGANIZATION
Stephen Hawking
PERSON
Michigan
LOCATION