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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
USA back to court for one reason. "I'll be very up-front with you," she said. Mot. Ex. E, p 2. 14 EFTA00077589 I want to make sure I'm not in a Chemical Battk[15] kind of situation, so I would like to know about contacts between the United States Attorney's Office and the Boies Schiller firm prior t
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
ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub
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
s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m
Entities connected to both Schiller and Chemical

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Prince Andrew
PERSONJane Doe
PERSON
Stephen Hawking
PERSONLoretta A. Preska
PERSONColleen McMahon
PERSONthe Southern District
LOCATIONMartindell
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONSecond Circuit
ORGANIZATION
Eric Schmidt
PERSONJeffrey Pagliuca
PERSON
Michael Jackson
PERSON