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n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which then comp
(1984) 5 United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988) 12 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 10 United States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 5, 6, 7 United States v. Taylor, 745 F.3d 15 (2d Cir. 2014) 12 US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12
n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Ma
(1984) 5 United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988) 12 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 10 United States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 5, 6, 7 United States v. Taylor, 745 F.3d 15 (2d Cir. 2014) 12 US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12
n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Ma
(1984) 5 United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988) 12 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 10 United States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 5, 6, 7 United States v. Taylor, 745 F.3d 15 (2d Cir. 2014) 12 US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12
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
225, 233 United States v. Stein, 456 F.2d 844 (2d Cir. 1972) 68 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 142, 143 United 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 1
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
grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d 945, 957 (11th Cir. 2020) ("It follows that when officers act with `an
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
grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d 945, 957 (11th Cir. 2020) ("It follows that when officers act with `an
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
1992) 150, 154 United States v. Stein, 456 F.2d 844 (2d Cir. 1972) 46 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 99 United 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
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
grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d 945, 957 (11th Cir. 2020) ("It follows that when officers act with `an
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
grossly negligent disregard for Fourth Amendment rights."' United States v. Raymonda, 780 F.3d 105, 117-18 (2d Cir. 2015) (quoting United States v. Stokes, 733 F.3d 438, 443 (2d Cir. 2013)); see also United States v. Green, 981 F.3d 945, 957 (11th Cir. 2020) ("It follows that when officers act with `an
(1984) 5 United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988) 12 United States v. Stein, 541 F.3d 130 (2d Cir. 2008) 10 United States v. Stokes, 733 F.3d 438 (2d Cir. 2013) 5, 6, 7 United States v. Taylor, 745 F.3d 15 (2d Cir. 2014) 12 US Bank Nat. Ass 'n v. PHL Variable Ins. Co., No. 12
Page: EFTA00018999 →n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which then comp
Page: EFTA00019004 →not actively investigating her. That understanding, as it turned out, was incorrect, but it was a misunderstanding deliberately encouraged by Boies Schiller with cooperation from the government. If Boies Schiller had disclosed that material Judge Sweet ordered them to disclose, Maxwell would have invoked
Page: EFTA00019013 →Entities connected to both Schiller and Stokes

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
United States
LOCATION
George W. Bush
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Prince Andrew
PERSONColleen McMahon
PERSON
Vicky Ward
PERSONLoretta A. Preska
PERSONDoug Band
PERSONthe Southern District
LOCATIONSweet
PERSON
Virginia Giuffre
PERSONJane Doe
PERSON
Michael Jackson
PERSON
Alan Dershowitz
PERSON