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t the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions. Id. at 21
utors] who are not merely partisan advocates, but public officials charged with administering justice honestly, fairly and impartially." Morales v. Portuondo, 165 F. Supp. 2d 601, 612 (S.D.N.Y. 2001). 24 EFTA00077599 In turn, this already high standard ratchets up even higher when a prosecutor appears
3, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.N.Y. 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 Unit
Page: EFTA00028931 →appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had a "complet
Page: EFTA00028939 →, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 2001) 24 Rea v. United States, 350 U.S. 214 (1956) 20 United States v. Bout, 731 F.3d 233 (2d Cir. 2013) 23 United States
Page: EFTA00029102 →appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had a "complet
Page: EFTA00029110 →Entities connected to both Schiller and Portuondo

Jeffrey Epstein
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONJane Doe
PERSONLoretta A. Preska
PERSON
Stephen Hawking
PERSONSecond Circuit
ORGANIZATIONColleen McMahon
PERSONJeffrey Pagliuca
PERSON
Boies Schiller
ORGANIZATIONMartindell
PERSONSweet
PERSON
Boies Schiller Flexner LLP
ORGANIZATIONStephen Rex Brown
PERSONSigrid McCawley
PERSONChemical Bank
ORGANIZATION
Eric Schmidt
PERSONCohen & Gresser LLP
ORGANIZATION