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r than the subject of the subpoena, was the moving party). During the conference, the Government was not able to explain why it, rather than Boles Schiller, made the application. Boles Schiller is perfectly capable of protecting its own interests. The law firm's failure to seek for itself permission to
To Be Filed Under Seal to use at a trial, rather than seeking information as part of a criminal investigation or grand jury proceeding. See also Botha v. Don King Productions, Inc., No. 97-cv-7587, 1998 WL 88745, at *3 (S.D.N.Y. Feb. 27, 1998) ("[T]he Government may not use its `awesome' investigat
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
e, 924 F.2d 434 (2d Cir. 1991) 158 Mum v. Yaretsky, 457 U.S. 991 (1982) 143 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 24 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 148 Boyd v. United States, 116 U.S. 616 (1886) 145
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
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
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
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
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
e, 924 F.2d 434 (2d Cir. 1991) 108 Blum v. Yaretsky, 457 U.S. 991 (1982) 99 Bochese v. Town of Ponce Inlet, 405 F.3d 964 (11th Cir. 2005) 20 Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) 102 Boyd v. United States, 116 U.S. 616 (1886) 101
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
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
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
against him"; and the Government did not seek the deposition "to aid it in a criminal investigation or grand jury proceeding." Id. at 700; see also Botha v. Don King Productions, Inc., No. 97 Civ. 7587 (JGK), 1998 WL 88745 (S.D.N.Y. Feb. 27, 1998) (noting importance of policy concerns of Martindell wh
Entities connected to both Schiller and Botha

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONColleen McMahon
PERSON
United States
LOCATIONJane Doe
PERSONMartindell
PERSONSweet
PERSONthe Southern District
LOCATIONLoretta A. Preska
PERSON
Stephen Hawking
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSONStokes
PERSON
Southern District of New York
ORGANIZATION
Prince Andrew
PERSONJeffrey Pagliuca
PERSONMartin Weinberg
PERSON