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aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not
scripts as a carrot, then suppression would be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold a hearing to determine whether the alleged misstatements or omissions
1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An
Page: EFTA00011453 →law firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Pomp Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not
Page: EFTA00011458 →scripts as a carrot, then suppression would be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold a hearing to determine whether the alleged misstatements or omissions
Page: EFTA00011472 →McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have any role in
Page: EFTA00029082 →aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not
Page: EFTA00029083 →scripts as a carrot, then suppression would be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold a hearing to determine whether the alleged misstatements or omissions
Page: EFTA00029097 →1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An
Page: EFTA00029817 →stify the government's secret, ex parte application . Ex. H, p 6. Judge Netburn also implicitly recognized what Judge McMahon never knew—that Boies Schiller was all too eager for the government to investigate and prosecute Maxwell: 6 Maxwell has not yet been provided discovery of whether Boies Schiller s
Page: EFTA00029830 →scripts as a carrot, then suppression would be warranted on that basis alone. Cf. Franks v. Delaware, 438 U.S. 154, 155-56 (1978); United States v. Rajaratnani, 719 F.3d 139, 146 (2d Cir. 2013) ("Franks instructs a district court to hold a hearing to determine whether the alleged misstatements or omissions
Page: EFTA00029836 →Entities connected to both Schiller and Rajaratnani

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSONJane Doe
PERSON
Stephen Hawking
PERSONColleen McMahon
PERSONSecond Circuit
ORGANIZATIONJeffrey Pagliuca
PERSON
Boies Schiller
ORGANIZATION
Michael Cohen
PERSONMartindell
PERSONStephen Rex Brown
PERSON
Boies Schiller Flexner LLP
ORGANIZATIONChemical Bank
ORGANIZATION
Valentine
PERSON
Boles
PERSONCohen & Gresser LLP
ORGANIZATION
United States
LOCATION
Martha Stewart
PERSON