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that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020). The defendant's request for the entire diary is likely to sweep in a signific
ernment obtains the boots and makes them available for inspection by the defendant, at which time Request 10 will be moot. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys (212) 637-2324 cc: Counsel of Record (by ECF) EFTA00103755
Adviser Michael Flynn despite his guilty plea have commanded more national attention. But outspoken critics, including Cohen and celebrity attorney Michael Avenatti, may be getting worse treatment, some legal observers said." CYBER DIVISION US Indicts Hackers Working With China To Steal COVID-19 Vaccines, Treat
otect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshir
Adviser Michael Flynn despite his guilty plea have commanded more national attention. But outspoken critics, including Cohen and celebrity attorney Michael Avenatti, may be getting worse treatment, some legal observers said." Cyber Division US Indicts Hackers Working With China To Steal COVID-19 Vaccines, Trea
rotect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshi
Adviser Michael Flynn despite his guilty plea have commanded more national attention. But outspoken critics, including Cohen and celebrity attorney Michael Avenatti, may be getting worse treatment, some legal observers said." EFTA00150027 CYBER DIVISION US Indicts Hackers Working With China To Steal COVID-19
otect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshi
ial jurors, to incriminating evidence that the law has determined may not be used to support a conviction"), cited with approval in United States a Avenatti , (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020). Based on these cases, the Court may make specific findings supporting the sealin
aged a dramatic, forced entry at dawn into her home and arrested her. EXHIBIT A, at 3. Immediately after Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press conference and made numerous comments attacking Ms. Maxwell's credibility and expressing her opinion of Ms. Maxwell's guilt, e.g., tha
Adviser Michael Flynn despite his guilty plea have commanded more national attention. But outspoken critics, including Cohen and celebrity attorney Michael Avenatti, may be getting worse treatment, some legal observers said." CYBER DIVISION US Indicts Hackers Working With China To Steal COVID-19 Vaccines, Treat
otect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshi
that something useful will turn up." Barnes, 2008 WL 9359654, at *4 (alteration and internal quotation marks omitted); see, e.g., United States v. Avenatti, No. 19 Cr. 373 (PGG), 2020 WL 508682, at *4 (S.D.N.Y. Jan. 31, 2020). The defendant's request for the entire diary is likely to sweep in a signific
Page: EFTA00015870 →ernment obtains the boots and makes them available for inspection by the defendant, at which time Request 10 will be moot. Respectfully submitted, AUDREY STRAUSS United States Attorney by: Is/ Assistant United States Attorneys cc: Counsel of Record (by ECF) EFTA00015873
Page: EFTA00015873 →aged a dramatic, forced entry at dawn into her home and arrested her. EXHIBIT A, at 3. Immediately after Ms. Maxwell's arrest, Acting U.S. Attorney Audrey Strauss held a press conference and made numerous comments attacking Ms. Maxwell's credibility and expressing her opinion of Ms. Maxwell's guilt, e.g., tha
Page: EFTA00021862 →al jurors, to incriminating evidence that the law has determined may not be used to support a conviction"), cited with approval in United States v. Avenatti , (S1) 19 CR 373 PGG, 2020 WL 70952, at *3 (S.D.N.Y. Jan. 6, 2020). Based on these cases, the Court may make specific findings supporting the sealin
Page: EFTA00021867 →Entities connected to both Michael Avenatti and Audrey Strauss

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Michael Cohen
PERSON
Donald Trump
PERSONthe Southern District
LOCATIONSouthern District
LOCATION
Denver
LOCATIONLeon Black
PERSON
William Barr
PERSON
New Hampshire
LOCATION
Alison J. Nathan
PERSON
United States
LOCATION
Colorado
LOCATION
Jared Kushner
PERSONMartin Weinberg
PERSON
George W. Bush
PERSON
Steven Mnuchin
PERSON