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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
ers do not create a genuine issue as to any material fact. United States v. Carving, 968 F.2d 232, 236 (2d Cir. 1992), abrogated on other grounds by Ratzlaf v. United States, 510 U.S. 135 (1994. Moreover, it is well settled that a material issue of fact sufficient to justify an evidentiary 112 EFTA0007
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
ers do not create a genuine issue as to any material fact. United States v. Carving, 968 F.2d 232, 236 (2d Cir. 1992), abrogated on other grounds by Ratzlaf v. United States, 510 U.S. 135 (1994. Moreover, it is well settled that a material issue of fact sufficient to justify an evidentiary 112 EFTA0003
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
779 F.2d 861 (2d Cir. 1985) 77, 80, 81 Peck v. United States, 73 F.3d 1220 (2d Cir. 1995) 112 Rakas v. Illinois, 439 U.S. 128 (1978) 82, 83 Ratzlaf v. United States, 510 U.S. 135 (1994) 112 vii EFTA00095074 Rawlings v. Kentucky, 448 U.S. 98 (1980) 83 Richardson v. Marsh, 481 U.S. 200 (1
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
ers do not create a genuine issue as to any material fact. United States v. Carving, 968 F.2d 232, 236 (2d Cir. 1992), abrogated on other grounds by Ratzlaf v. United States, 510 U.S. 135 (1994), Peck v. United States, 73 F.3d 1220 (2d Cir. 1995). Moreover, it is well settled that a material issue of fa
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
ers do not create a genuine issue as to any material fact. United States v. Carving, 968 F.2d 232, 236 (2d Cir. 1992), abrogated on other grounds by Ratzlaf v. United States, 510 U.S. 135 (1994. Moreover, it is well settled that a material issue of fact sufficient to justify an evidentiary 112 EFTA0010
Entities connected to both Schiller and Ratzlaf

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONJane Doe
PERSONLoretta A. Preska
PERSON
Stephen Hawking
PERSONColleen McMahon
PERSONJeffrey Pagliuca
PERSONMartindell
PERSONSweet
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
United States
LOCATION
Boies Schiller
ORGANIZATIONStephen Rex Brown
PERSON
Eric Schmidt
PERSONMartin Weinberg
PERSON
Michael Jackson
PERSON