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19) 278 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 252 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 274 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014) 137 United States v. Cornielle, 171 F.3d 748 (2d Cir. 1999) 60, 77, 78, 85 United States v. Corr, 543 F.2d 1042 (
r 18, 2018. Shortly thereafter, in or about December or January 2018, the Government indicated to at I that it intended to make document requests. Schiller generally advised the Government that a protective order would govern some of the materials. (Id. at 3). In or about February 2019, approximately t
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
19) 186 United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) 165 United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) 182 United States v. Corbett, 750 F.3d 245 (2d Cir. 2014) 97 xi EFTA00095078 United States v. Cornielle, 171 F.3d 748 (2d Cir. 1999) 42, 53, 58 United States v. Corr, 5
bpoenas and Ex Pane Applications for Materials SOW- after opening t mment identified possible victims and their counsel trroiigh ich ina Boies Schiller. (Def. Mem. 3, Ex. E at 2-3). SDNY first cont oies Schiller about its investigation on or about December 18, 2018. Shortly thereafter, in oar Dec
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
t complying with any of the specific procedures or exceptions provided in the [confidentiality] orders." Id. Here, by contrast, ga on in late 0111 Schiller shortly the na in Februan Miran order, Aside from rank speculation loosely premised on an anonymously sourced news report, the defendant offers n
whether a witness was encouraged to speak, but whether his "free will," when he spoke, "was overborne." Id. at 188; see also, e.g., United States v. Corbett, 750 F.3d 245, 253 (2d Cir. 2014). It follows that the Government need not inform a witness of the nature of its investigation, see United States
ast, the Government accurately conveyed to Chief Judge McMahon the opening of its investigation in late 2018, the reason it made contact with Boies Schiller shortly thereafter and served a subpoena in February 2019, and that no documents governed by the protective order had yet been produced. Aside from
Entities connected to both Corbett and Schiller

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONColleen McMahon
PERSON
Stephen Hawking
PERSONJane Doe
PERSON
United States
LOCATIONthe Southern District
LOCATION
Prince Andrew
PERSON
George Mitchell
PERSONLoretta A. Preska
PERSON
Eric Schmidt
PERSON
Virginia Giuffre
PERSONMartindell
PERSONSweet
PERSON
Michael Jackson
PERSONMartin Weinberg
PERSON
Colorado
LOCATION