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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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was 121 EFTA00095213 addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards require the jury to determine whet
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
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed." United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (quotation marks omitted). A statement made in a civil deposition is also material if "a truthful
natural tendency to influence, or [be] capable of influencing, the decision of the decisionmaking body to which it was addressed," United States v. Gaudin, 515 U.S. 506, 509 (1995) (alteration in original) (internal quotation marks omitted). Neither of these standards requires the jury to determine whe
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
No. 98 Cr. (KIK), 1999 WL 9848 (S.D.N.Y. Jan. 11, 1999) 275,281 United States v. Gambino, 838 F. Supp. 744 (S.D.N.Y. 1993) 70 United States v. Gaudin, 515 U.S. 506 (1995) 182, 184,200,222 United States v. Geanev, 417 F.2d 1116 (2d Cir. 1969) 284 United States v. Gentile, 235 F. Supp. 3d 649
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
No. 98 Cr. (JGK), 1999 WL 9848 (S.D.N.Y. Jan. II, 1999) 183, 189 United States v. Gambino, 838 F. Supp. 744 (S.D.N.Y. 1993) 48 United States v. Gaudin, 515 U.S. 506 (1995) 122, 135, 148 United States v. Geaney, 417 F.2d 1116 (2d Cir. 1969) 191 United States v. Gentile, 235 F. Supp. 3d 649 (D.
Entities connected to both Schiller and Gaudin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
United States
LOCATION
Supreme Court
ORGANIZATION
Medina
PERSON
Bradley Edwards
PERSONThompson
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Southern District of New York
ORGANIZATIONWerner
PERSONNejad
PERSONSampson
PERSONForde
ORGANIZATIONChacko
PERSONMarkiewicz
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Napolitano
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Scarlett Johansson
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Adriana Ross
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