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dge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evidence controlled by Boies, Schiller, and Flexner ("BSF") lawyers working with the government on behalf of alleged (now-adult) witnesses. In her ex-parte application, Ms. Maxwell provi
n of the government. See 18 U.S.C. § 3500(a) (applies exclusively to statements "in the possession of the United States"); see also United States v. Bin Laden, 397 F. Supp. 2d 465, 491 (S.D.N.Y. 2005) ("The statute thus establishes three essential elements EFTA00096514 The Honorable Alison J. Nathan Ma
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
0 United States v. Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 268 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 298, 300 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) 240 United States v. Birney, 686 F.2d 102 (2d Cir. 1982) 61, 65 United States v. Birrell, 470 F.2d 113 (2d
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
. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage fr
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
. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage fr
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
Biaggi, 675 F. Supp. 790 (S.D.N.Y. 1987) 176 United States v. Biaggi, 909 F.2d 662 (2d Cir. 1990) 205, 208 ix EFTA00095076 United States v. Bin Laden, 91 F. Supp. 2d 600 (S.D.N.Y. 2000) United States v. Birney, 686 F.2d 102 (2d Cir. 1982) United States v. Birrell, 159 43, 45 470 F.2d 113 (2d
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
Crim. P. 7(d), '[i]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage fr
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
. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez, 824 F. Supp. 351, 369 (S.D.N.Y. 1993)). "Motions to strike surplusage fr
Entities connected to both Schiller and Bin Laden

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Barack Obama
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSON
Bill Clinton
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Department of Justice
ORGANIZATION
David Boies
PERSON
Donald Trump
PERSON
Marc Rich
PERSON
Michael Jackson
PERSON
Bradley Edwards
PERSON
John F. Kennedy
PERSON
Joe Biden
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON